Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined a deficiency of $679.31 in petitioners' 1976 Federal income tax.
The sole issue for decision is whether $8,209.64 that petitioner received from the Gatke Corporation during 1976 is excludable from gross income as a gift under section 102.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
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