GIGNOUX, District Judge.
This is an action for refund of federal income taxes for the years 1959, 1960 and 1961 in the amounts of $1,736.75, $2,344.50 and $3,064.63, respectively. The only question presented is whether the amounts of the income of four trusts established by George B. Morrill, Jr., which the trustees applied to the payment of the tuition and room charges of the taxpayers' four minor children at private schools and colleges, were taxable
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