The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1940 in the amount of $4,181.79, denying petitioner's attempt to take advantage of the provisions of section 107 of the Internal Revenue Code.
FINDINGS OF FACT.
Petitioner filed his income tax return for the calendar year 1940 with the collector for the third district of New York.
In the year 1929 petitioner was substituted as one of the trustees for two trusts...
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