BEATTIE v. COMMISSIONER

Docket No. 7041.

6 T.C. 609 (1946)

ELIZABETH L. BEATTIE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 29, 1946.


Attorney(s) appearing for the Case

Charles F. Schnee, Esq., for the petitioner.

Lawrence R. Bloomenthal, Esq., for the respondent.


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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