The Commissioner has determined deficiencies in petitioner's income tax of $13,735.46 for 1940 and $15,363.47 for 1941.
The deficiency for 1940 is due to the addition to the net income of $31,703.98 reported by petitioner on her return, of $29,202.18 as income from trust under the will of Harold Hirsch. The Commissioner explained this adjustment in his deficiency notice as follows:
(a) It is held that the income from the trust under the will of Harold Hirsch...
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