Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in income tax for the year 1952 in the amount of $1,946.32 and an addition to tax under section 294(d), Internal Revenue Code of 1939, of $248.47.
The only questions for decision are (1) whether the amount of $6,691.88 received by petitioners from the Estate of Terrie H. Hadley was taxable income under...
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