MEMORANDUM OPINION
KISER, District Judge.
Virginia E. Holt, the income beneficiary of an inter vivos trust that she created in 1956, brought this action with her husband, Cecil T. Holt, to obtain an income tax refund of $29,270 for tax years 1982 and 1983, contending that the Internal Revenue Service improperly taxed income from the trust. Mrs. Holt's four children also are named as income beneficiaries...
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