Memorandum Opinion
LEECH, Judge:
This controversy involves income tax deficiencies for the calendar years 1938, 1940 and 1941 in the respective amounts of $123.12, $4,622.95 and $6,051.59. The sole issue is whether the income of a trust created by petitioner is taxable to her under sections 166, 167 or 22 (a) of the Revenue Act of 1938 and the Internal Revenue Code.
[The Facts]
The facts are found as stipulated. Briefly summarized...
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