OPINION.
SMITH, Judge:
This proceeding involves liabilities asserted against the petitioners as transferees for deficiencies in income tax of Bertha Stockstrom, now deceased, for the calendar years 1939, 1940, and 1941 in the respective amounts of $4,558.61, $5,624.64, and $10,545.03.
The question in issue is whether the income of three trusts created by decedent for the benefit of her children and grandchildren was taxable to her as settlor...
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