OPINION
NIMS, Judge:
Respondent determined a deficiency in the Federal income tax of petitioner's decedent for the taxable year 1975 of $98,222. Due to concessions, the issue for decision is the amount of gross income petitioner's decedent should have reported by virtue of having been during 1975 the income beneficiary of a simple trust earning only foreign source income.
All of the facts have been stipulated and are found accordingly.
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