The Commissioner determined deficiencies in petitioners' income tax for 1960 and 1961 in the amounts of $156,917.26 and $80,523.33, respectively. The only adjustments in controversy are those relating to the Commissioner's determination that petitioner Oliver G. Willits actually or constructively received certain trustee's commissions in the amounts of $178,887.88 in 1960 and $131,107.95 in 1961.
FINDINGS OF FACT
The stipulation of facts, along with accompanying...
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