Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent has determined deficiencies in petitioners' Federal income tax for the taxable years 1973, 1974 and 1975 in the amounts of $496.69, $565.05 and $310.77, respectively. The sole issue is whether amounts paid to petitioner Dr. Cusick by hospitals at which he worked as an intern or resident were scholarships or fellowship grants that may be excluded from gross income...
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