Memorandum Opinion
SCOTT, Judge:
Respondent determined a deficiency of $1,238.21 in the Federal income tax for calendar year 1973 for Dorothy Gulvin, now deceased, and Ward Gulvin.
Some of the issues raised by the pleadings have been disposed of by the parties, leaving for our decision only whether under sections 151 and 152, I.R.C. 1954,
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