On May 20, 1963, petitioners each made trust agreements in favor of their respective children. Simultaneously, petitioners, as trustees, formed a partnership, Tri-Continental Sales Company, which was to be exclusive sales agent for certain Japanese fabrics. Income from the sales of the fabrics was distributed to the trustees who filed the required fiduciary returns and paid taxes on the pro rata portions of the trust which were attributable to the individual beneficiaries...
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