Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in the petitioner's income tax in the amounts of $5,635.71 for 1940 and $12,544.64 for 1941. The only question for decision is whether the Commissioner erred in including in the petitioner's income for these two years the income of four trusts established by the petitioner for his four children and the income of several trusts which he established for the benefit of his first wife....
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