Memorandum Findings of Fact and Opinion
MELLOTT, Judge:
This proceeding involves the income tax liability of Katharine P. Loring for the calendar year 1939 in the amount of $1,456.15. She died after the petition was filed and the executors of her estate have been substituted as petitioners.
The sole issue is whether the sum of $11,403.50, received by the decedent under the circumstances hereinafter set out, constituted a loan or, as respondent determined...
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