United States Tax Court March 25, 1946, Docket No. 4658 (Wyant v. Commissioner)

OPINION.

Van Fossan, Judge-.

The issue raised by the pleadings, and as stated by the parties at the hearing, is confined to the question of whether or not the petitioner is taxable, under section 22 (a) of the Internal Revenue Code and the rule of Helvering v. Clifford, 309 U. S. 331, upon the income of the trusts created by him in 1934 and 1935.