OPINION
ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1960 in the amount of $179,519.58.
The parties having reached agreement with respect to one of the issues, the only issue remaining for decision is whether the transfer in 1960 by the petitioner, Myrtis C. Usher, of stock in Sarong, Inc., to a trust pursuant to an agreement wherein the trust agreed to pay her an annuity for her life, constituted...
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