Memorandum Findings of Fact and Opinion
DAWSON, Judge:
In these consolidated cases the respondent determined a deficiency of $7,596.61 in Lammot duPont's Federal gift tax for the quarter ended March 31, 1973, and a deficiency of $43,448.07 in petitioners' Federal income tax for the year 1973.
The two issues presented for decision involve circumstances related to the divorce of Lammot duPont and Betty duPont January 17, 1973. The issues are:
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