DAWSON, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $8,533.62 for 1964 and $7,669.87 for 1965. Petitioners have alleged in their petition overpayments of $2,285.16 for 1964 and $3,334.17 for 1965.
The principal question is whether petitioners have an amortizable cost basis in a joint life interest in a percentage of the income from an estate trust acquired in exchange for their transfer to the trust of certain shares...
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