Respondent determined a deficiency in income tax in the amount of $2,261.55 against petitioner for the taxable year 1941. On December 9 of that year the petitioner transferred certain securities to each of her four children in exchange for their separate written promises to pay the petitioner an annuity for her lifetime. Respondent treated this transaction as taxable under section 111 (a) and (b) of the Internal Revenue Code, by ascribing a "fair market value" of one-fourth...
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