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RUESTOW v. COMMISSIONER

Docket No. 8991-75.

37 T.C.M. 639 (1978)

T.C. Memo. 1978-147

Edward A. Ruestow and Margaret E. Rustow v. Commissioner.

United States Tax Court.

Filed April 17, 1978.

Attorney(s) appearing for the Case

Edward A. Ruestow, pro se, 36 Valley Rd., Old Westbury, N.Y. Jack H. Klinghoffer, for the respondent.

[37 T.C.M. 640]

Memorandum Findings of Fact and Opinion

FORRESTER, Judge:

Respondent has determined a deficiency in petitioners' Federal income taxes for the taxable year 1973 in the amount of $9,842. The sole issue for our decision is whether $28,000, of a $30,000 payment, which petitioner Edward A. Ruestow received upon termination of his association with a law firm, is excludable from his gross income as a gift.

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