This proceeding involves a deficiency in income tax for the calender year 1940 in the sum of $11, 558.85. The principal question to be determined is whether certain securities which passed to petitioner under circumstances hereinafter set forth constituted income to her in 1940 as compensation for past services, or a gift or bequest excludable from income under section 22 (b) (3) of the Internal Revenue Code. In the event that the securities are found to constitute income...
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