GOTT v. COMMISSIONER

Docket No. 29835.

12 T.C.M. 435 (1953)

Charles C. D. Gott v. Commissioner.

United States Tax Court.

Entered April 22, 1953.


Attorney(s) appearing for the Case

John R. Brook, Esq., for the petitioner. Rigmor O. Carlsen, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $26,299.33 in income tax of the petitioner for 1943. The only issue for decision is whether $41,869.51, paid by Self Winding Clock Company, Inc., in 1942 for two annuity contracts of which the petitioner was named beneficiary, was compensation for services and taxable income of the petitioner for that year.

Findings of Fact

The petitioner filed his return for 1943...

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