RAUM, Judge:
The Commissioner determined deficiencies in petitioners' income tax in the following amounts:
Docket No. Petitioner 1980 1981 21381-84 Harry M. Bedell, Jr. - - - $810.00 21382-84 Bedell Trust $17,857.73 15,021.48
The issue presented for decision is whether the Estate of Harry M. Bedell, Sr., Trust (the trust or the Bedell Trust)
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