Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined a deficiency of $1,278.93 in petitioner's income tax for the year 1944, chiefly by reason of his holding that "The income of the trust is held to be taxable to you as grantor since such income is used to fulfill your legal obligations." At the hearing, after petitioner's counsel had stated his case fully, respondent's counsel declined the opportunity offered to make a statement as to his position...
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