Memorandum Opinion
LEECH, Judge:
This proceeding involves deficiencies in income taxes as follows:
1938 ................... $2,787.68 1939 ................... 6,374.26
The two issues involved are: (1) Whether the income from a trust created by the petitioner wherein he reserved the power to modify or alter the provisions with respect to distributions to the beneficiaries is taxable under section 22 (a) of the Revenue Act...
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