HOLMES, Circuit Judge.
The Tax Court sustained deficiencies assessed by the Commissioner with respect to 1936, 1937, and 1938 income tax returns of Andrew Jergens, and the taxpayer has petitioned for review. The correctness of the decision depends upon whether or not the entire income of a trust created by petitioner's wife was taxable to petitioner.
Prior to December 31, 1934, Mrs. Jergens had received 923 shares of common stock in the Andrew Jergens Company...
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