MULRONEY, Judge:
Respondent determined a deficiency in petitioners' income tax for the year 1962 in the amount of $14,943.28.
The issue is whether $39,666.66, the net amount received by petitioner Joseph M. Mariani in 1962 in settlement of a suit against his father's estate, is excludable from gross income as a gift or inheritance under section 102, I.R.C. 1954.
FINDINGS OF FACT
Some of the facts are stipulated...
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