This proceeding involves a deficiency in income tax determined by respondent for the taxable year 1945 in the amount of $9,193.03. It is attributable to respondent's inclusion in petitioner's 1945 gross income of certain dividends received by a trust of which petitioner is life beneficiary. The only issue is whether such dividends are properly so includible.
FINDINGS OF FACT.
The facts, which have been stipulated, are so found and made a part hereof.
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