Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined a deficiency in income tax in the amount of $3,222.07, together with a negligence penalty of $161.10, for the calendar year 1945. The issues are (1) whether the income from certain securities owned by petitioner allegedly as a trustee is taxable to him, and (2) whether the negligence penalty was correctly imposed.
Findings of Fact
Most of the facts were stipulated...
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