The Commissioner determined a deficiency of $184.95 in income tax for the taxable year ended December 31, 1941, by adding to income reported $1,399.17 paid to petitioner's wife by the Commonwealth of Pennsylvania pursuant to the provisions of the Act of June 7, 1917, as amended. (65 Purdon's Pa. Stat. Ann., secs. 111-113.)
Petitioner assails the determination on the ground that the payment to petitioner's wife was a nontaxable gift.
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