Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1964 in the amount of $78,364.45.
The issues for decision are:
(1) Whether $122,535.36 in cash and securities transferred to petitioner Alfred Altman by Charlotte Altman on December 15, 1964, is includable in petitioners' gross income for the taxable year 1964.
(2) If the $122,535.36 is includable...
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