SIMONS, Circuit Judge.
The petitions assail decisions of the Board of Tax Appeals sustaining determinations of the respondent, that the income of an irrevocable trust created for the benefit of the petitioner's wife and stepsons, is taxable to the grantor. While other grounds in support of the assessment were urged, the Board's decision, two members dissenting, was based solely upon the doctrine of Douglas v. Willcuts,
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