Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in income tax against petitioners for the years and in the amounts as follows:
Year Deficiency _______________________________________ 1976 ............ $3,374.99 1977 ............ 4,936.64 1978 ............ 3,403.95
There are essentially two issues in this case, whether income from two grantor trusts established...
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