Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a $5,016 deficiency in petitioners' joint individual Federal income tax for calendar year ending December 31, 1982.
This case is presently before the Court on respondent's Motion for Summary Judgment filed pursuant to Rule 121.
The issues for decision are whether (1) certain payments made to petitioners under title VII of the Regional Rail Reorganization Act of 1973...
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