ARUNDELL, Judge:
This proceeding involves an income tax deficiency of $135,097.15 for the taxable year ended December 31, 1937, the amount in controversy being approximately $128,716.38.
Two issues are presented for our determination. The first concerns the question of whether a dividend consisting of stock, which was received by the trustees of a testamentary trust, was properly allocated to the trust corpus and taxable to the trust, or constituted...
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