United States Tax Court.
Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioners' Federal income taxes for the taxable year 1973 in the amount of $9,842. The sole issue for our decision is whether $28,000, of a $30,000 payment, which petitioner Edward A. Ruestow received upon termination of his association with a law firm, is excludable from his gross income as a gift.
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