Memorandum Opinion
RAUM, Judge:
Respondent determined a deficiency in income tax in the amount of $675.00 for the year 1959.
The sole issue is whether petitioners are entitled to exclude from gross income as a gift a portion of the amounts received by John F. McManus from the Benz Kid Company during the year 1959.
All of the facts have been stipulated.
John F. McManus and Helen McManus, husband and wife, filed a joint income tax return...
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