Milton L. Hildebran and Judy W. Hildebran - Page 1

                                 T.C. Memo. 2004-42                                   

                               UNITED STATES TAX COURT                                

              MILTON L. HILDEBRAN AND JUDY W. HILDEBRAN, Petitioners v.               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13978-01.             Filed February 19, 2004.              

               G. Paul Martin, for petitioner.                                        
               Veena Luthra, for respondent.                                          

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               CHIECHI, Judge:  Respondent determined deficiencies of                 
          $7,168 and $7,621 in petitioners’ Federal income tax for taxable            
          years 1998 and 1999, respectively.                                          
               The issue remaining for decision is whether certain wages              
          that petitioner Milton L. Hildebran (Mr. Hildebran) received                
          during each of the years at issue are excludable from petition-             

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