ELLIOTT, District Judge.
The sole issue in this case is whether the income of two trusts created by C. F. Williams was taxable to him as the grantor-trustee of the trusts for the years 1953 and 1954 by virtue of the provisions of Internal Revenue Code of 1939 and in particular U. S. Treas.Regs. § 39.22(a)-21. The parties concede that if the income of the trusts was not taxable to the grantor-trustee during 1953 and 1954, the plaintiffs (taxpayers) are entitled...
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