Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined a deficiency of $654.59 in the petitioner's income tax for 1953. The sole issue is whether the amount of $2,200 received by petitioner in 1953 from the University of Minnesota to support a research project was a gift within the meaning of section 22(b) (3) of the Internal Revenue Code of 1939
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