SIMONS, Ciruit Judge.
The petitioner seeks review of the redetermination by the Tax Court of a deficiency in his income tax for 1940 and deficiencies in gift taxes for 1940 and 1941. The income tax deficiencies were the result of additions by the Commissioner to income of dividends received upon stock placed in trust for the taxpayer's sister and children, and declared taxable under § 22(a) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 22(a)...
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