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WILSON v. COMMISSIONER

Docket No. 92910.

39 T.C. 362 (1962)

CHARLES WILSON AND GOLDIE MAE WILSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 6, 1962.

Attorney(s) appearing for the Case

Thomas N. Chambers, Esq., for the petitioners.

Dennis J. Fox, Esq., for the respondent.

BRUCE, Judge.

Respondent has determined a deficiency in income tax for the year 1957 in the amount of $1,716.50.

The primary issue herein is whether the amount paid for an annuity for petitioner by his employer is includable in petitioners' gross income for the year 1957. The resolution of this issue depends upon (1) whether petitioner Charles Wilson's rights in the annuity contract were nonforfeitable within the meaning of section 403(c), I.R.C. 1954...

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