ATKINS, Judge:
Respondent determined deficiencies in income tax of petitioners for the years 1954, 1955, and 1956 in the respective amounts of $2,688.70, $4,583.80, and $5,455.05.
The only issue presented is whether there should be included in the income of the petitioner Morris Zeltzerman the amounts used by the Morrison and the Lancaster Hospitals in acquiring annuity contracts for the petitioner or on account of the receipt by the petitioner of rights...
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