ROFF v. COMMISSIONER

Docket No. 68200.

36 T.C. 818 (1961)

HARRY ROFF AND MARCIA ROFF, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 10, 1961.


Attorney(s) appearing for the Case

Jerome R. Miller, Esq., for the petitioners.

Arthur Pelikow, Esq., for the respondent.


BRUCE, Judge:

Respondent determined deficiencies in Federal income taxes for the years 1954 and 1955 in the amounts of $2,232.98 and $1,044.77, respectively. The issues presented for our determination are: (1) Whether increments realized upon the sale of annuity policies are taxable as ordinary income or as long-term capital gain; and (2) if said increments are taxable as ordinary income, whether the provisions of section...

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