This proceeding is brought to test the correctness of respondent's action in determining a deficiency in the petitioners' individual income tax for the taxable year 1948 in the amount of $196.58.
The sole issue herein is whether the sum of $1,000 received by the petitioner Leon D. Hubert, Jr., from the Louisiana State Law Institute during the taxable year 1948 is taxable income within the meaning of section 22 (a) of the Internal Revenue Code, or whether it is a gift...
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