Memorandum Findings of Fact and Opinion
LEECH, Judge:
This proceeding seeks a redetermination of deficiencies in income tax for the years 1939 and 1940 in the respective amounts of $1,106.70 and $1,470.01. The issues are: (1) whether all the income of the John Koehrer trust for the years 1939 and 1940 is taxable to the grantor, and (2) whether the sums received by the taxpayer pursuant to "life annuity" contracts during the years 1939 and 1940 were annuity...
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