Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined deficiencies in income tax for 1956, 1957, and 1958 in the respective amounts of $9,086.16, $6,460.91, and $1,615.76. The issue is whether the amount received in each year from the corporation which employed petitioner's deceased husband is a nontaxable gift excludable from gross income under section 102(a) of the Code, or is taxable income under section 61(a) (1), as respondent...
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