MAJOR, Chief Judge.
Petitioner, Frances McGuire Rassas, and her husband, George J. Rassas, on December 29, 1947, created a trust in which they named their twenty-day old daughter, Denice, as beneficiary and themselves as trustees. The assets conveyed to themselves as trustees consisted of stock in two corporations. Petitioner and her husband filed separate income tax returns for the year 1947, showing an aggregate net income of $49,682.16. For the same year, petitioner...
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