OPINION.
SMITH, Judge:
This proceeding is for the redetermination of a deficiency in income tax for the calendar year 1940 in the amount of $21,654.14. Certain of the issues have been settled by stipulations of the parties. The sole remaining issue is whether the respondent has properly included in petitioner's income, as distributable income of a trust of which she was life beneficiary, a portion of the income of the trust for the taxable year which...
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