Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
Respondent determined a deficiency of $13,665 in petitioners' Federal income tax for the calendar year 1971. We must decide (1) whether the $70,192.93 petitioners received from one John Henho on May 9, 1971, is excludable from their gross income as the proceeds of a gift under section 102, Internal Revenue Code of 1954,
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