Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Year Deficiency 1982 ..................... $1,245.29 1983 ..................... 2,179.00
After concessions by petitioners, the sole issue for decision is whether amounts received by petitioner Michael E. Newman during the years at issue constitute...
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