Memorandum Opinion
OPPER, Judge:
Respondent has determined a deficiency of $8,249.05 in petitioner's 1939 income tax, which petitioner contests in this proceeding. All of the facts are stipulated and are hereby found accordingly. Petitioner has an office in Boston, Massachusetts, and filed the estate income tax return for 1939 with the collector for the district of Massachusetts.
The question is whether income of the residue of an estate in process...
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