party to this appeal because she joined her husband in filing an income tax return for the tax year 1980


2
 J. Paul had five sons in all:  Ronald;  George Franklin Getty II (George, Jr.), who died in 1973 without surviving issue;  Eugene Paul Getty (Paul, Jr.);    Gordon Peter Getty (Gordon);  and Timothy Ware Getty, who died in 1958 without surviving issue


3
 On December 31, 1934, J. Paul executed a document waiving his right to income from the shares of stock he had contributed to the trust.  The effect of this waiver was that approximately 20% of the income from the trust was paid to income beneficiaries other than J. Paul during his lifetime


4
 Section 102 states in relevant part:
(a) GeneralAustralian media giants Fairfax and Nine to merge

SYDNEY: Publisher Fairfax Media and Nine Entertainment on Thursday announced plans to merge, creating an integrated Australian media giant across television, online video streaming, print, and digital.

Fairfax Media and Nine Entertainment have announced plans to merge - the new media giant will be called Nine, with Fairfax ceasing to exist, drawing the curtain on a venerable brand that has been an Australian staple for more than 170 years

Under the deal, Nine will effectively be the dominant partner, with its shareholders owning 51.1 percent of the combined entity and Fairfax shareholders owning the rest.

The new company will include Nine's free-to-air television network, Fairfax's radio interests and mastheads -- including The Sydney Morning Herald and The Age in Melbourne -- and a suite