Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency of $11,496.37 in gift tax for the calendar year 1942. The sole issue is whether a lump sum payment of $70,000, or any portion thereof, made by Julien H. Hill (hereinafter referred to as decedent) to his wife in 1942, during the pendency of divorce proceedings and incident thereto, in settlement solely of his wife's right to support and maintenance, is taxable as a gift...
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