Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in the amount of $1,744.86 in the income tax of petitioners for the taxable year 1949. The sole issue is whether respondent erred in determining that certain shares of stock or funds used to purchase such shares were received by one of the petitioners as taxable income, rather than as a gift excludible from income pursuant to section 22(b)(3) of the Internal...
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