Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in petitioner's income tax for the year 1948 in the amount of $9,534.13. The issues presented are (1) whether the income of a trust, established by the petitioner, for 1948 is taxable to him pursuant to Sections 22 (a), 166 or 167 of the Internal Revenue Code, and (2) whether certain expenses, claimed by the trustee in its 1948 fiduciary income tax return are deductible in full against...
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