Memorandum Opinion
WITHEY, Judge:
The respondent has determined a deficiency in petitioner's income tax for 1953 in the amount of $131.
The sole issue presented for our decision is the correctness of the respondent's action in determining that a portion of the capital losses of a testamentary trust may not be deducted by the income beneficiary in computing his taxable income.
All of the facts have been stipulated and are found accordingly...
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