Alpena Savings Bank v. Commissioner

*669OPINION.

Smith :

The respondent has determined deficiencies in income and excess profits taxes against petitioner for 1934. To the extent that the taxes are attributable to income in respect of its unsegregated assets, the petitioner now concedes liability; in other words, it concedes that it is liable for deficiencies in income and excess profits taxes for 1934 in the respective amounts of $310.33 and $112.85, which it claims already to halve paid.

The sole question in issue is whether the petitioner is liable to income tax for 1934 in respect of the income of a trust of segregated assets which…