Memorandum Findings of Fact and Opinion
TURNER, Judge:
The respondent determined deficiencies in the petitioner's income tax of $15,117.07, $5,930.70 and $3,740.51 for the years 1939, 1940 and 1941, respectively. The only issue presented is the correctness of the respondent's action in determining that the dividends on certain stock were taxable to petitioner, the said stock, according to petitioner, having been held not as his own but by him as trustee...
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