ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years 1959, 1960, and 1961 in the respective amounts of $40,569.77, $40,900.22, and $18,714.29.
The parties having settled certain issues by stipulation, the issue remaining is whether the portion of the petitioner's stock held in 1959 in the name of the Estate of Henry Rhiel Garden was, in reality, held by a trust, thereby precluding classification of the petitioner...
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