Memorandum Opinion
SMITH, Judge:
This proceeding involves income tax deficiencies for 1937, 1938, and 1939 in the respective amounts of $6,637.68, $8,036.96, and $7,990.30. The deficiencies result from respondent's determination that petitioner is an association taxable as a corporation.
[The Facts]
Petitioner was created in 1909 under a trust agreement entered into by the following named eight children and grandson of Elizabeth...
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