SWAN, Circuit Judge.
These petitions present the question whether income of a trust established by the petitioners is taxable to them under the provisions of section 167(a) (2) of the Revenue Acts of 1932 and 1934, 26 U.S.C.A. Int.Rev.Code, § 167(a) (2). In each act the section reads as follows: "(a) Where any part of the income of a trust * * * (2) may, in the discretion of the grantor or of any person not having a substantial adverse interest in the disposition...
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