MANTON, Circuit Judge.
Petitioner seeks a review of a deficiency assessment against her for income taxes for 1929. It is based upon petitioner's failure to include, in her return, dividends in the sum of $47,250. representing accumulated dividends of $31,500 and current dividends of $15,700, all paid to the trustees of an irrevocable trust which petitioner created February 5, 1929. On that date, she conveyed 3,000 shares of cumulative preferred stock of Sidney Blumenthal...
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