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  5. 51 T.C.M. 963 (1986)
 

AMABILE v. COMMISSIONER

Docket No. 1283-84.

51 T.C.M. 963 (1986)

T.C. Memo. 1986-180

Charles Amabile and Carmela Amabile v. Commissioner.

United States Tax Court.

Filed May 1, 1986.

Attorney(s) appearing for the Case

John F. Papsidero, for the petitioner. Anne M. DiFonzo, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:*

Respondent determined a deficiency in petitioners' Federal income tax for the taxable years 1979 and 1980 in the amounts of $2,838 and $5,457, respectively. The only issue presented is whether under section 6771 Charles Amabile should be treated as the owner of 100 per cent and 50 percent, respectively, of two trusts.

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