OPINION.
LEECH, Judge:
The respondent has determined deficiencies in income and victory tax for the calendar year 1943 in the total of $2.353.31, and a deficiency in income tax for the calendar year 1944 in the sum of $1,221.05. Deficiencies for both of these years arise from respondent's action in including in petitioner's income for those years certain dividends received by the trustee of a trust of which the petitioner was a secondary income beneficiary...
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