MEMORANDUM OPINION
GOEKE, Judge:
These cases arise from petitions for judicial review filed in response to the notices of deficiency mailed to Kenneth W. Stejskal, Sr. and Jane Stejskal and to several of their trusts. Pursuant to a stipulation of settled issues, the income and expenses of the alleged trusts have now been collapsed into the tax liabilities of Kenneth and Jane Stejskal (petitioners). The sole remaining issue for decision is the proper amount...
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