Memorandum Findings of Fact and Opinion
This proceeding has been initiated to test the correctness of respondent's determination of a deficiency in income tax in the sum of $86.33 for the calendar year ended December 31, 1940. The issue raised is the deductibility of the sum of $600 alleged to be the amount of an annuity payment made by petitioner in excess of the purchase price of the same which resulted from the fact that the annuitant outlived her life expectancy...
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