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STONE v. COMMISSIONER

Docket No. 42788.

23 T.C. 254 (1954)

GEORGE WINCHESTER STONE, JR., AND HELLEN DEAN STONE, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 17, 1954.

Attorney(s) appearing for the Case

Roswell Magill, Esq., and Albert Rosenblum, Esq., for the petitioners.

George E. Grimball, Jr., Esq., for the respondent.

This proceeding involves a deficiency of $178.04 in income tax for the calendar year 1950. The sole issue is whether the amount of $1,000 received by the petitioner George Winchester Stone, Jr., from the John Simon Guggenheim Foundation is taxable income or a gift. The petitioners filed a joint return for 1950 with the collector of internal revenue at Baltimore, Maryland.

FINDINGS OF FACT.

The petitioners reside...

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