Memorandum Findings of Fact and Opinion
GOFFE, Judge:
Respondent determined a deficiency of $46,778.74 in petitioners' Federal income tax for the year 1964.
The principal issue presented for decision is whether the receipt by petitioner Jerome Kass from his father in 1964 of 24 shares of stock in Trinity Apartments, Inc., constituted compensation for services under section 61(a), Internal Revenue Code of 1954,
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