Memorandum Findings of Fact and Opinion
OPPER, Judge:
By these consolidated proceedings petitioners challenge respondent's determination of deficiencies for 1939 as follows:
John F. Nixon ................. $472.29 Theresa B. Nixon .............. 515.29
The question presented is whether amounts awarded in 1939 by the Orphans Court of Pennsylvania to petitioners as life beneficiaries of a trust constitute taxable income...
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