Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $27,129.16 in the petitioner's income tax for the year 1939.
The issues now in controversy are:
(1) Whether or not the net income of the Amy Branch Jergens Trust constituted taxable income to the petitioner, under the provisions of section 22(a) of the Internal Revenue Code.
(2) Whether or not the petitioner is entitled to deduct from his gross income, as provided...
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