Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined deficiencies in income tax of $1,100.32, $920.21 and $778.87 for the calendar years 1937, 1938 and 1939, respectively, and penalties for 1937 and 1938 of $275.08 and $230.05, respectively. The deficiencies result from respondent's action in including in petitioner's income for those years all of the income realized in such years by a trust created by petitioner, of which he and...
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