Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined that a deficiency in the income tax of petitioner exists for the taxable year 1960 in the amount of $441.86. Petitioner makes claim for overpayment of income tax for the same year in the amount of $847.18 The sole issue is whether certain payments made to petitioner by the State of Massachusetts during 1960 are excludable from her taxable income as gifts.
Findings...
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