Memorandum Findings of Fact Opinion
The Commissioner determined deficiencies in petitioner's income taxes for the calendar years 1938 and 1939 in the respective amounts of $2,919.10 and $3,803.81, as a result of including in her taxable income that part of the income of two trusts used to pay premiums on insurance on petitioner's life. Petitioner challenges the correctness of respondent's determination on the theory that petitioner was not the grantor of the trusts...
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