Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This case involves a deficiency in income tax in the amount of $8,494.79 for the year 1944. The petition also alleges overpayment in the amount of $2,658.51.
The only issue to be determined is whether the net proceeds of a life insurance policy held on the life of one Patrick H. Adams, in the amount of $19,645.24, should be included in petitioner's gross income for the year 1944.
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