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The judgment of the Tax Court will be modified to provide for the award of a reasonable attorney’s fee on this appeal. As modified, the judgment of the Tax Court is affirmed.

Inasmuch as the parties in this action are related to one another, a brief summary of their background is appropriate
The petitioner Lillian T. Hicks’ family background is as follows: She and her brother, James A. Hicks, received identical 20% shares in 1928 of the assets of a partnership known as “The Hicksville-Overly Company,” which was organized by their father in 1924. In 1935, by a state court divorce decree, a trust was established for Lillian, and the remaining 80% of the partnership’s assets were conveyed to Lillian’s trustee. In 1957, Lillian, as trustee, sold her 80% interest to her brothers, James and Robert Hicks, for $150,000, and the profits from the sale were placed in trust for the benefit of all three brothers, their respective sons and the issue of their sons.

The Tax Court allocated 100% of the gain from the