The Commissioner determined a deficiency of $1,629.57 in the income tax of Emanuel Sturman for the calendar year 1943. Since the hearing of this case Emanuel Sturman died and his estate has been substituted as the proper party in this proceeding and will be referred to herein as the petitioner. The question presented is as to whether income of a trust paid to the wife of the grantor during 1942 and 1943 is taxable to the petitioner.
FINDINGS OF FACT.
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