Respondent has determined deficiencies of $3,024.89 and $12,411.86, in the 1940 and 1941 income tax liability of J. M. Mannon, Jr., now deceased. Adjustments resulting from clerical errors, additional and nontaxable income, and additional and unallowable deductions are not disputed. The only issue is whether decedent was taxable on one-half of the ordinary income of four trusts set up with community funds by decedent and his wife for the benefit of the wife and minor children...
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