This proceeding involves deficiencies in income tax for the years 1939 and 1940 in the respective amounts of $20,558.50 and $22,029.02. Two issues are raised by the pleadings, the second being raised by the respondent in an amended answer in which he seeks increased deficiencies. Stated generally, the first question is whether a retired employee is required to include in his gross income the amount received by him as "retirement payments" under a contract with an insurance...
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