United States Tax Court.
Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined deficiencies in petitioner's income taxes for the years and in the amounts as follows:
1951.............. $98,795.42 1952.............. 93,046.05 1953.............. 83,930.89
The issues for decision are:
(1) Whether one or multiple trusts were created by a trust instrument; and
(2) the proper allocation of depletion allowances...
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