United States Board of Tax Appeals April 26, 1933, Docket No. 58311 (Trust No. 5522 & Trust No. 5644, Bellehurst Syndicate v. Commissioner)

*1257OPINION.

Smith :

The petitioner first alleges that:

(a) Tiie Commissioner iias erroneously treated tlie Petitioner as an association and proposes to tax it as sucli, whereas the Petitioner is a Trust with no taxable income.

On brief, the petitioner states: “1. The first issue we submit without argument.