Memorandum Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1980 and 1981 in the amounts of $10,094.17 and $6,245, respectively. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision only whether income earned by Wendell Phillips, (petitioner) from employment by the Panama Canal Commission during the years 1980 and 1981 is exempt from...
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