Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a deficiency in petitioners' 1975 income tax of $5,773, plus an addition to tax for negligence under section 6653(a)
1. Whether the purported conveyance by petitioner Daniel W. Cole of his lifetime services to a family trust effectively shifted the incidence of taxation on compensation paid to him but transferred...
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