Respondent determined a deficiency in income tax against the petitioner for the year 1939 in the amount of $2,448.29. The parties have agreed to certain adjustments which will be settled under Rule 50. The issue is whether petitioner, as an income beneficiary of certain trusts, is taxable upon the value of stock received by the trusts during the taxable year. The determination of this issue involves the question as to whether the stock was received as part of a nontaxable...
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