Respondent has determined deficiencies in income tax for the calendar years 1944 and 1945 in the amounts of $2,033.84 and $1,270.18, respectively. Petitioner concedes the existence and has consented to the assessment of deficiencies in income tax of $955.74 for the taxable year 1944 and $353.80 for the taxable year 1945.
The sole question presented is whether the petitioner in 1940 established a pension trust within the meaning of section 23 (p) and section 165 of...
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