Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in income tax for the years and in the amounts as follows:
Year Amount 1955 ....................... $8,748.03 1956 ....................... 7,083.01
The issues are whether income received by petitioner Emerson R. Miller, in his capacity as trustee, is includible in petitioners' individual income for the years 1955 and 1956...
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