Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined deficiencies against petitioner Charles M. Peisner for the taxable years and in the amounts as follows:
Calendar Year Deficiency 1945............ $47,333.52 1946............ 19,575.34
The sole issue in this case is whether the trustees of the separate trusts, established for petitioner...
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