Respondent determined deficiencies in the income tax of petitioner of $23,223.33 for the year 1941 and $10,745.61 for the year 1943.
The deficiencies arose out of the purchase in 1941 of a single premium annuity contract based on petitioner's life by his employer corporation which retained all rights thereunder until 1943, when it transferred the contract to petitioner by endorsement.
On brief respondent concedes that no deficiency should be asserted for the...
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