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ABDELLA v. COMMISSIONER

Docket No. 3077-80.

46 T.C.M. 1602 (1983)

T.C. Memo. 1983-616

Jamie L. Abdella and Leota T. Abdella v. Commissioner.

United States Tax Court.

Filed September 28, 1983.

Attorney(s) appearing for the Case

Thomas N. Chambers and James R. Snyder, Charleston, W. Va., for the petitioners. Robert J. Kastl, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent has determined a deficiency of $13,426.40 in petitioners' 1976 Federal income tax. The sole issue is whether a payment of $30,000 to petitioners was a nontaxable gift under section 102(a).1

Findings of Fact

Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached thereto are incorporated herein by...

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