Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined deficiencies in income tax of $1,178.05 and $3,306.80 for the calendar years 1940 and 1941, respectively. The issues are: (a) whether respondent in determining the deficiencies erred in his inclusion in gross income of the decedent for those years income received by 5 trusts created for the benefit of his 4 children; and (b) did respondent err by including in the income of decedent...
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