OPINION
TANNENWALD, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the year 1970 in the amount of $61,086.39. The sole issue is whether a lottery prize won by a minor, together with income earned thereon, which is made payable under the applicable State law to his parents as custodians, constitutes income in the year the prize is awarded or in the year the money is actually turned over to him by his parents.
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