This proceeding was brought for a redetermination of a deficiency of $4,622.78 in petitioner's income tax for 1940.
The only litigated issue is the inclusion in petitioner's income, under the 3 per cent annuity provision of Internal Revenue Code, section 22 (b) (2), of $4,910.43 representing a portion of the amounts received by petitioner from certain insurance companies in 1940.
The case was submitted upon a stipulation of facts and evidence adduced at the...
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