The respondent determined deficiencies in income tax against I. A. Wyant for the years 1940 and 1941 in the respective amounts of $2,119.86 and $6,411.97.
The sole issue is whether the respondent erred in determining that the petitioner, as grantor, is taxable under section 22 (a) of the Internal Revenue Code upon the income of eight inter vivos trusts created for the benefit of his eight children.
FINDINGS OF FACT.
The petitioner is an individual...
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