Memorandum Opinion
FAY, Judge:
Respondent determined a $12,898.00 deficiency in petitioners' 1975 Federal income taxes. The issues presented are (1) whether petitioners are taxable on income purportedly assigned to a so-called family equity trust, and (2) whether respondent is estopped from asserting the deficiency by a "no-change" letter sent to the trust.
All of the facts have been stipulated and are found accordingly.
At the time they...
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