GRAVEN, Senior District Judge (by assignment).
This is an action by taxpayers to recover income tax deficiencies, penalties and interest assessed by and paid to the District Director of Internal Revenue for the taxable years 1952 and 1953.
On July 25, 1952, Rufus C. Salley (hereinafter referred to as "plaintiff") wrote to the deputy commissioner of Internal Revenue requesting a ruling on the federal tax treatment of an annuity contract and an annuity loan...
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