TRAIN, Judge:
Respondent has determined deficiencies in petitioners' income taxes for 1956 and 1957 in the respective amounts of $10,785.34 and $2,895.43.
The issues presented in this case are:
(1) Whether certain payments to Mary C. Westphal in 1956 and 1957 by a corporation, of which her husband was president prior to his death on June 21, 1956, constitute taxable income to her; and
(2) Whether the excess of deductions over gross income...
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