TUTTLE, Circuit Judge.
The sole issue on this petition for review is whether certain payments made to Messrs. Wallace and Hambleton in 1946, 1947 and 1948 by their employer, the Great American Reserve Insurance Company, were gifts or compensation for services rendered. The Tax Court held that they were compensation and therefore taxable income under 26 U.S.C.A. § 22(a).
The material facts were stipulated, and those facts are fully stated in the Tax Court...
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