Supplemental Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
This case is again before us, this time on remand from the United States Court of Appeals for the Ninth Circuit. In our earlier opinion, we held that the transactions in question did not constitute a sale or exchange for an annuity but a transfer in trust, with the result that the $16,502 annual payment received by petitioner from the trustees was includable in her gross income under...
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