Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in the income taxes of petitioners for the taxable years 1956 and 1958 in the amounts of $60,684.74 and $22,100.35, respectively.
The only issue for decision is to what extent did the petitioners realize income where they, as grantors, transferred stock in trust upon the condition that the trustee discharge their gift tax liability arising by virtue of the transfer...
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