Memorandum Opinion
HOYT, Judge:
The respondent determined deficiencies for the taxable years 1955 and 1956 of $2,170.42 and $8,268.54, respectively. The parties have stipulated that no deficiency is due for the year 1956. The only remaining issue is whether $10,000 paid to the petitioner in 1955 under the provisions of a codicil to a will is excluded from gross income as a bequest under section 102 of the 1954 Code or whether it was in payment for past services...
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