The Commissioner determined deficiencies in petitioner's income tax for the years 1961, 1962, and 1963 in the amounts of $5,170.03, $5,201.10, and $5,303.96, respectively. The sole issue presented arises out of petitioners' transfer of a building, designed and constructed exclusively for use by petitioner Sidney W. Penn in his medical practice, to eight trusts for petitioners' four minor children, of which Sidney Penn served as sole trustee. The precise question for decision...
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