OPINION.
SMITH, Judge.
This proceeding is for the redetermination of a deficiency in income tax for 1939 of $19,069.85. The petition alleges that the respondent erred in the determination of the deficiency:
(1) By taxing as ordinary income the amount of $60,553.77 received by the petitioner from two trust funds which had been created by Chrysler Corporation.
(2) By increasing taxable dividends in the amount of $1,164.
The second...
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