Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1959 in the amount of $1,384.19 and an addition to tax, under section 6651 of the Internal Revenue Code of 1954, of $346.05.
The issues presented are: (1) whether the sale of certain real property by a trust (the income of which is taxable to petitioner J. Fleet Cowden under section 671 of the Internal Revenue Code of 1954...
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