Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding was brought for a redetermination of deficiencies in income tax of $29,438.27 and $637.16 for the years 1939 and 1940, respectively.
The primary issue is whether a transaction between petitioner's decedent and her children, pursuant to which decedent transferred certain stock to the respective children and obtained from them a promise to pay her an annuity, resulted in long-term...
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