SCOTT, Judge:
The respondent determined a deficiency in petitioners' income tax for the taxable year 1954 in the amount of $3,740.61. The only issue for decision is whether the amount of $10,000 received by Harold L. Regenstein in 1954 from the Metropolitan Life Insurance Company is taxable as ordinary income rather than as long-term capital gain.
FINDINGS OF FACT.
The petitioners are husband and wife whose income tax return for the year 1954...
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