Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
The Commissioner determined deficiencies of $2,704.02 and $4,841.76 in petitioner's income taxes for 1939 and 1940, respectively, in part by adding to income reported the income of an irrevocable trust which petitioner created, reserving the right of management and directing that the income be distributed in amounts determinable by her among such of sixteen named beneficiaries as she should indicate...
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