United States Board of Tax Appeals January 30, 1932, Docket No. 41444. (Mulqueen v. Commissioner)

lead-opinion

*444OPINION.

Sternhagen:

The petitioning executrix, having admittedly received the amounts in question from Lamb, omitted them from the *445estate’s income-tax return, and now urges that such omission was proper because the amounts were gifts from Lamb and hence were not within statutory gross income as described in section 213 (a), Revenue Acts of 1924 and 1926, but were expressly