Memorandum Opinion
CLAPP, Judge:
Respondent determined a $19,010.20 deficiency in petitioners' 1984 Federal income tax and a $4,752.47 addition to tax under section 6661(a). The case was submitted fully stipulated under Rule 122. Following concessions by both parties, the only issue is whether a $50,000 payment that Doris Zelinsky received from her employer in 1984 was a gift or taxable income.
Petitioners resided in New Haven, Connecticut when they...
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