WILBUR, Judge:
Respondent determined the following deficiencies in the Federal income tax of two trusts:
Ernestine M. Carmichael Trust No. 21-35 1972 ------ $54,388.83 1973 ------ 329.97 Irrevocable Living Trust Created by Ella L. Morris for Ernestine M. Carmichael No. 21-32 1972 ------ $1,041.36
The sole issue for decision is whether...
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