The Commissioner determined deficiencies against Emil and Lottie Morton for the calendar years 1960, 1961, and 1962 in the amounts of $5,500.67, $621.33, and $24,559.76 respectively, and an addition to tax under section 6651(a) of $155.33 for the year 1961. The question for decision is whether the incomes and losses ascribed to three trusts established by Emil Morton should be attributed to him.
FINDINGS OF FACT
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