Memorandum Opinion
OPPER, Judge:
Respondent determined a deficiency in petitioner's income tax for 1943 of $244.52 by including in his taxable income a payment of $750, which petitioner omitted on the ground that it was a gift from his employer. All of the facts are hereby found as stipulated by the parties. Petitioner's income tax return was filed with the collector for the first district of New York.
Upon the completion of forty years of service...
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