MARIS, Circuit Judge.
This is a petition for the review of a decision of the Board of Tax Appeals that there was a deficiency in the petitioner's income taxes for the years 1933 and 1934. The facts, as found by the Board, are substantially as follows:
On January 21, 1929, the petitioner created an irrevocable trust designating himself and The Union Trust Company of Pittsburgh as trustees. The net income of the trust, when and as received, was payable to the...
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