Memorandum Opinion
SMITH, Judge:
This proceeding involves income tax deficiencies for 1939, 1940 and 1941 in the respective amounts of $407.77, $4,409.07, and $8,625. The deficiencies result entirely from the inclusion in petitioner's gross income of the income of three trusts which he had created for the benefit of his wife and two minor children.
Most of the essential facts have been stipulated.
[The Facts]
Petitioner is...
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