Memorandum Opinion
ARUNDELL, Judge:
The Commissioner determined income tax deficiencies for the years 1938 and 1939 in the respective amounts of $2,287.99 and $11,541.19. The issue is whether the income of a trust created by petitioner is taxable to him under sections 22(a) and/or 167(a)(3) of the Revenue Act of 1938 and the Internal Revenue Code. Petitioner's returns were filed in the first district of Illinois. Most of the facts have been stipulated.<...
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