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TIBERTI v. COMMISSIONER

Docket No. 89138.

21 T.C.M. 961 (1962)

T.C. Memo. 1962-174

Jelindo A. Tiberti and Marietta Tiberti v. Commissioner.

United States Tax Court.

Filed July 25, 1962.

Attorney(s) appearing for the Case

Mark Townsend, Esq., for the petitioners. Walter S. Weiss, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

Respondent determined deficiencies in income taxes for the years and in the amounts which follow:

  Year                      Deficiency

  1955 .................    $46,705.91
  1956 .................     16,474.15
  1957 .................     75,491.32

The sole question for our determination is whether trusts created by petitioners...

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