STERRETT, Judge:
By statutory notice dated March 6, 1978, respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1974 and 1975 in the amounts of $4,189.47 and $4,839.76, respectively. The sole issue for decision is whether certain payments received by petitioner Melvin A. Yarlott, Jr., during the years in issue qualify for exclusion from gross income pursuant to section 117, I.R.C. 1954.
FINDINGS OF FACT
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