Memorandum Opinion
DAWSON, Judge:
Respondent initially determined a deficiency in petitioner's Federal income tax for the year 1965 in the amount of $315,162.11. In his amended answer filed on March 22, 1971, respondent claimed an increased deficiency of $424,714.06, resulting in a total asserted deficiency of $739,876.17.
The issues presented for decision are: (1) Did the petitioner realize taxable income of any kind in 1965 resulting from the gift...
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