Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioner's gift tax for the period ending December 31, 1976 in the amount of $73,326.20. The issues for decision are (1) whether petitioner's release and cancellation of a note from petitioner's former wife, Elizabeth, payable to petitioner, in December of 1976, having a balance then due of $117,199.07, was a gift...
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