OPINION.
MURDOCK, Judge:
The Commissioner determined a deficiency of $6,222.98 in the income tax of the petitioners for 1947. The only issue is whether $11,213, representing the value of an annuity contract distributed to the petitioner Percy S. Lyon in 1947 was taxable as income. The parties have presented the facts by a stipulation which is adopted as the findings of fact.
The petitioners, husband and wife, filed a joint income tax return...
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