This case involves a deficiency in income tax determined by the respondent for the calendar year 1950 in the amount of $5,237.33 with an addition to tax under section 294 (d) (2) of the Internal Revenue Code of 1939 in the amount of $889.06. The respondent now concedes that there should be no addition to tax under section 294 (d) (2). The only question remaining for our decision is whether the respondent erred in determining that capital gains of the Carolyn Solomon Trust...
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