MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Jonathan B. Geftman petitioned the Court to redetermine respondent's determination of a $13,043 deficiency in his 1985 Federal income tax, a $3,261 addition thereto under section 6651(a), and a $754 addition thereto under section 6654(a).
We must decide:
1. Whether amounts paid to petitioner, as sole beneficiary of a trust, are includable in his 1985 gross...
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