BRUCE, Judge:
The respondent determined a deficiency in income tax in the amount of $13,321.89 for the calendar year 1959. Two issues are presented for decision: (1) Whether an amount paid to a life insurance company pursuant to a certain contract constituted salary income to William S. Bolden, and (2) whether the fair market value of a pension trust policy received by him in 1959, less his basis therein, is taxable at ordinary income rates in the year received...
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