Memorandum Opinion
OPPER, J.:
This proceeding brings into issue deficiencies in income tax for the years 1938 and 1939 in the respective amounts of $43.65 and $2,533.76.
The facts as submitted by the parties by stipulation and exhibits thereto are hereby found accordingly. Petitioner filed his individual income tax return for the taxable years in question with the collector of internal revenue, 14th District, Albany, New York.
Since the trust...
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