Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in the income tax of the petitioner for the year 1946 in the amount of $4,178.57. The sole issue to be determined is whether the sum of $16,999.92 received by the petitioner during the year 1946 constitutes taxable income or a gift.
Findings of Fact
Malcolm Hart, petitioner herein, filed an individual income tax return for the year 1946 with the collector of internal...
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