TIETJENS, Judge:
The Commissioner determined a deficiency in income tax for the period August 9, 1951, to December 31, 1951, in the amount of $2,922.66.
The question for decision is whether the sum of $9,968.83 paid by a corporation to the estate of its deceased president (the estate being the petitioner) is taxable income of the estate as additional compensation or is excludible from gross income as a gift.
FINDINGS OF FACT.
Some...
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