The Commissioner determined a deficiency in petitioner's income and victory tax liability for 1943 in the amount of $19,810.25. The question to be determined is whether there is includible in petitioner's income for 1942 and 1943 rental income of $16,105.60 and $29,360.11, respectively, reported in partnership returns for 1942 and 1943 as distributable to trusts created by petitioner on January 2, 1941, for the benefit of each of his four minor children.
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