FAY, Judge:
Respondent determined deficiencies of $7,225 and $6,732 in petitioners' Federal income taxes for 1974 and 1975, respectively. The only issue for decision is what part of a trust created by petitioner-husband is to be treated as being owned by him during 1974 and 1975 under section 675(3).
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Petitioners Larry W...
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