The Commissioner determined a deficiency of $15,575.62 in petitioner's income tax for 1945. The following issues are presented:
(1) When a surviving widow renounces a usufruct under Louisiana law, is the renunciation effective for income tax purposes from the date of its execution, or is the renunciation retroactive to the date of the husband's death?
(2) May respondent reallocate income among joint owners in a manner disproportionate to their ownership interests...
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