The Commissioner determined income tax deficiencies for 1966 and 1967 in the amounts of $164,249.51 and $257,362.64, respectively, against petitioner, a testamentary trust created under the last will and testament of Alfred I. duPont. Among petitioner's assets is "Nemours," an elaborate estate, which during the years in issue served as the principal residence of Jessie Ball duPont, Mr. duPont's widow and the principal beneficiary as well as a trustee of petitioner. At issue...
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