GARDNER, Circuit Judge.
This is a petition to review a decision of the Tax Court of the United States determining a deficiency in petitioner's income tax for the calendar year 1939, in the sum of $39,383.64. The facts were stipulated and as stipulated embodied in findings entered by the Tax Court.
On December 23, 1939, petitioner created a trust under the terms of which he transferred to trustees 640 shares of the capital stock of the P. D. George Company...
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