SOPER, Circuit Judge.
The petition for review involves deficiencies in income taxes for the years 1941 and 1943 which were found by the Tax Court to exist by reason of the failure of the taxpayer to include in her return the income from two one-fourth shares in a restaurant business which she had given in trust to her two minor children. The Tax Court considered the circumstances under which the children's interests were acquired and held, and came to the conclusion...
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