STRUM, Chief Judge.
Plaintiff, Frank D. Bisbee, sues to recover a deficiency assessment of $387.86, levied against him as additional income tax for 1940, in the following circumstances:
Under the will of the late William A. Bisbee, who died in 1911, all his property was left in trust for the benefit of his widow and two children, one-third of the net income to be paid to each during the lifetime of the widow, the corpus to be divided between the children,...
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