Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $42,801.78 in petitioner's Federal income tax for the year 1966.
We must decide whether the amount of $75,000 received in 1966 by petitioner, a licensed practical nurse, from an elderly friend and patient should be treated as a gift or as compensation for services.
Findings of Fact
Certain facts have been stipulated by the parties. The stipulation...
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