Memorandum Findings of Fact and Opinion
This proceeding was initiated to test the correctness of respondent's determination of deficiencies in income taxes for the years 1936 and 1937 in the respective amounts of $1,470.10 and $1,971.66. These deficiencies are based on the inclusion by respondent in petitioner's income of certain sums received by the decedent Garland from the income of a trust created by him primarily for the benefit of his former wife and their...
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