Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the income tax of Ella B. Hollingsworth for the calendar year 1964 in the amount of $406,941.79. The issue for decision is whether Mrs. Hollingsworth received $548,170 of funds from a break-in at the plant of her estranged husband, John D. Hollingsworth, during the year 1964, which sum she converted to her own use.
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