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BEGGY v. COMMISSIONER

Docket No. 50777.

23 T.C. 736 (1955)

JOHN F. BEGGY AND ROSE A. BEGGY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 27, 1955.

Attorney(s) appearing for the Case

W. Denning Stewart, Esq., for the petitioners.

Albert J. O'Connor, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner determined a deficiency of $5,744.30 in income tax of the petitioners for 1950. The only issue for decision is whether $26,368.48 paid by Mine Safety Appliances Company to John F. Beggy in 1950 represented a gift within the meaning of section 22 (b) (3) of the Internal Revenue Code and therefore was excludible from his income. The parties have filed a stipulation of...

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