OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $9,753.19 in income tax of the petitioners for 1954. The facts have been presented by a stipulation which is adopted as the findings of fact.
The petitioners, husband and wife, filed their joint return with the director of internal revenue for the Lower Manhattan District of New York.
The only issue for decision is whether $20,000 paid by Arturo in 1954 to Pauline...
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