Memorandum Opinion
RAUM, Judge:
The Commissioner determined a $2,869 deficiency in the 1977 income tax of petitioners, husband and wife, who filed a joint return for that year. The sole issue presented is whether payments of $26,130 received in 1977 by the husband (hereinafter sometimes referred to as the petitioner) were excludable from gross income under section 104(a)(1), I.R.C. 1954. The facts have been stipulated.
Petitioner was employed by...
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