Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding is for the redetermination of deficiencies in income tax for 1939, 1940, and 1941 of $7,145.53, $8,427.38, and $9,762.79, respectively. The questions in issue are (1) whether the respondent erred in including in gross income the net income of a trust created by the petitioner in 1934 for the benefit of his wife and daughter in the amounts of $12,913.13 for 1939, $13,455.41 for 1940, and...
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