United States Tax Court November 30, 1981, Docket Nos. 4805-79, 16171-79 (Smith v. Commissioner)

OPINION

Tannenwald, Chief Judge:

Respondent has determined deficiencies in petitioners’ Federal income tax for the calendar years 1975 and 1976 in the respective amounts of $4,495 and $4,948.78. The sole issue for decision is whether petitioners are entitled to exclude from their gross income amounts received by Joseph T. Smith as overtime pay while employed by the U.S.