This proceeding involves a deficiency in income tax for the calendar year 1940 in the sum of $493.02. In addition to other adjustments not in dispute, respondent determined that the income of two trusts, totaling $830, of which petitioner was sole trustee, was taxable to him individually under section 22 (a) of the Internal Revenue Code.
FINDINGS OF FACT.
Petitioner is an attorney practicing in New York City and resides at University Gardens, Great Neck...
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