OPINION.
SMITH, Judge.
This proceeding involves income tax deficiencies for 1940 and 1941 in the respective amounts of $36,939.12 and $28,237.24. The question for determination is whether petitioner is taxable in 1940 and 1941 on the income of four trusts which he had previously established for the benefit of four of his infant children. Two other minor issues raised in the pleadings have been settled by stipulation. The facts pertaining to the issue...
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