Memorandum Opinion
TYSON, J.:
This proceeding involves an income tax deficiency in the amount of $1,026.38 for the calendar year 1937, not all of which is in controversy.
The only issue presented is, whether the respondent erred in including in petitioner's gross income the amount of $5,582.92 representing payments made to petitioner in 1937 by The Equitable Life Assurance Society of the United States.
The proceeding has been submitted upon...
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