Memorandum Opinion
SMITH, Judge:
The respondent has determined a deficiency of $3,206.84 in petitioner's income tax for 1940. The only question in issue is whether petitioner is taxable on the income of a trust which he created for the benefit of his son and others, naming himself and the son trustees and retaining the right to change the beneficiaries or beneficial interests at any time. The facts have been stipulated.
[The Facts]
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