Memorandum Findings of Fact and Opinion
A deficiency has been determined for the taxable year 1937 in the amount of $9,593.03. In his deficiency notice respondent states "that the income of the Lois A. Spanel Trust is taxable to you under the provisions of Section 22(a) of the Revenue Act of 1936 as amended." The issue arises out of this determination and by the further averment in respondent's answer that the income in question is also taxable under section 167...
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