Charles C. D. Gott, Petitioner, v. Commissioner of Internal Revenue, Respondent, 212 F.2d 205 (2d Cir. 1954)
Annotate this CaseDecided April 27, 1954
Petition to review a decision of the Tax Court redetermining a deficiency in the income taxes of the petitioner and holding the cost of two annuity contracts to constitute taxable income under § 22 (b) (2) (B) of Title 26 U.S.C.A.
John R. Brook, George V. Mahoney, New York City, for petitioner.
H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, C. Moxley Featherston, Sp. Assts. to the Atty. Gen., for respondent.
Before CHASE, Chief Judge, and SWAN and FRANK, Circuit Judges.
PER CURIAM.
Affirmed on the opinion of the Tax Court, 12 T.C.M. 435.
Bogardus v. Commissioner, 302 U.S. 34, 58 S. Ct. 61, 82 L. Ed. 32, on which the petitioner much relies, is distinguishable on the facts.
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