Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined income tax deficiencies for the calendar years 1939 and 1940 in the amounts of $13,819.25 and $4,531.13, respectively. Some of the adjustments are not in controversy here. The sole question is whether certain distributions made during the taxable years by the executor Burchenal, to himself as testamentary trustee, are deductible by the estate under section 162 (c) of the Internal...
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