OPINION.
DISNEY, Judge:
This case involves income tax for the calendar year 1941. The Commissioner determined a deficiency of $284.06. The taxpayer contends that there is an overpayment of $175.42. The only issue presented is whether petitioner shall pay income tax upon an annuity received, based upon the total value of property transferred in the acquisition thereof, or whether a part of such value shall be considered a gift.
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