Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent has determined deficiencies in the petitioners' Federal income tax as follows:
Year Amount 1968 .............. $ 2,681.09 1969 .............. 12,706.68 1970 .............. 8,096.04
Due to concessions by the parties, the following issues remain for decision:
1. Whether the pension trust created pursuant to section 401(a)
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