Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $26,299.33 in income tax of the petitioner for 1943. The only issue for decision is whether $41,869.51, paid by Self Winding Clock Company, Inc., in 1942 for two annuity contracts of which the petitioner was named beneficiary, was compensation for services and taxable income of the petitioner for that year.
Findings of Fact
The petitioner filed his return for 1943...
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