Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $2,435 in petitioners' Federal income tax for 1976 together with an addition to tax in the amount of $122 under section 6653(a)
The issues for decision are as follows:
1. Whether the assignment and transfer of petitioners' salaries earned in 1976 to a so-called family trust were effective to relieve...
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