JAMESON, District Judge:
The United States has appealed from a judgment in favor of Jayne M. Perkins based on a decision of the district court holding that certain annuity payments made by Perkins constituted losses on a transaction for profit rather than capital expenditures and accordingly were deductible losses pursuant to 26 U.S.C. § 165(c)(2) (1976). We reverse.
I. Factual Background1
In late 1963, taxpayer...
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