SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1957 and 1959 in the amounts of $1,981.28 and $1,286.23, respectively.
The issues for decision are:
(1) Whether the gain realized by petitioners upon the transfer of a remainder interest in each of two trusts after the death of the life tenant but prior to distribution, constitutes ordinary income or long-term capital gain.
(2) Whether...
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