Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined a deficiency of $9,148.44 in income tax for the year 1940. The only question for determination is whether petitioner, as grantor of a trust, is taxable on a dividend of $24,006.95 received by the trust after December 11, 1940, when the trust was made irrevocable. Petitioner concedes that income received by the trust prior to December 11, 1940, is taxable to him.
Petitioner...
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