Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income taxes of petitioner as follows:
Calendar Year Deficiency 1948 .......... $11,953.47 1949 .......... 12,499.96 1950 .......... 9,980.02
The question presented is whether petitioner is taxable upon income received and reported by the executor of an estate of which petitioner was the residuary beneficiary...
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