MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge.
Respondent determined a deficiency in petitioner's Federal income tax return of $974 for 1998. Unless otherwise indicated, subsequent section references are to the Internal Revenue Code in effect for the year in issue. The sole issue for decision is whether the $4,017 of unemployment compensation petitioner received during 1998 is includable in his gross income for that year.
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