Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined a deficiency in petitioners' income tax for the calendar year 1957 in the amount of $2,838.02.
The sole issue for decision is:
Where the petitioners created a recorded mortgage lien on certain apartment house realty which they owned, and then conveyed said property subject to the encumbrance, by gift to a family trust which thereafter operated the property for...
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