Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $1,316.45 in petitioners' Federal income tax for the year 1974. Concessions have been made by the parties. The issues remaining for decision are:
(1) Whether income received by petitioner-husband for sales commissions and management services is taxable to him or to a "family trust" purportedly created by petitioners; and
(2) Whether $1,750 paid in...
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