WINTER, Circuit Judge:
In 1968 and 1969, Mrs. Mae Pearson paid long-term capital gains taxes on certain monies—termed by the parties as "special death benefits"—received by her from the Graybar Electric Company (Graybar), her deceased husband's former employer. She sued for a refund of these taxes, claiming that they were erroneously paid because the amounts paid to her by Graybar were gifts, excluded from gross income under § 102(a) of the Internal...
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