Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent has determined a deficiency in petitioner's Federal income tax for the taxable year ended December 31, 1965, in the amount of $12,830.
The sole issue presented for our decision is whether certain amendments to a pension trust adopted after the 15th day of the third month following the close of the taxable year 1965, but made retroactive...
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