Memorandum Opinion
TURNER, Judge:
The respondent has determined deficiencies in income tax against the petitioner for the years 1939 and 1940 in the amounts of $1,096.34 and $2,141.40, respectively. The principal question is whether the petitioner is taxable on the entire amount of income distributed by a trust created by him to his divorced wife for the maintenance and support of their two minor children, or whether, since a part of the trust income was...
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