Memorandum Findings of Fact and Opinion
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 sole issue is whether, and if so, to what extent, gain realized by petitioners upon the transfer of remainder interests in each of two trusts after the death of the life tenants but prior to distribution, constitutes ordinary income.
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