Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the year 1959 in the amount of $3,694.99.
The only issue for decision is whether the transfer of certain property and money by one Florence Murray to the petitioners resulted in taxable income to the petitioners or whether the transfer was nontaxable as a gift.
Findings of Fact
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