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  • Charles C. D. Gott v. Commissioner of Internal Revenue, 212 F.2d 205, 2d Cir. (1954)

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    The United States Court of Appeals for the Second Circuit affirmed the decision of the Tax Court which held that the cost of two annuity contracts constituted taxable income under Section 22(b)(2)(B) of Title 26 of the U.S. Code for the petitioner. The Tax Court's opinion was affirmed in a per curiam opinion by the Second Circuit, which found that the case cited by the petitioner, Bogardus v. Commissioner, was distinguishable on the facts from this case.

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    Filed: 1954-04-27 Precedential Status: Precedential Citations: 212 F.2d 205 Docket: 22875_1

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    The United States Court of Appeals for the Second Circuit affirmed the decision of the Tax Court which held that the cost of two annuity contracts constituted taxable income under Section 22(b)(2)(B) of Title 26 of the U.S. Code for the petitioner. The Tax Court's opinion was affirmed in a per curiam opinion by the Second Circuit, which found that the case cited by the petitioner, Bogardus v. Commissioner, was distinguishable on the facts from this case.

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    Charles C. D. Gott v. Commissioner of Internal Revenue, 212 F.2d 205, 2d Cir. (1954)

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    The United States Court of Appeals for the Second Circuit affirmed the decision of the Tax Court which held that the cost of two annuity contracts constituted taxable income under Section 22(b)(2)(B) of Title 26 of the U.S. Code for the petitioner. The Tax Court's opinion was affirmed in a per curiam opinion by the Second Circuit, which found that the case cited by the petitioner, Bogardus v. Commissioner, was distinguishable on the facts from this case.

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    of 1

    212 F.

    2d 205

    Charles C. D. GOTT, Petitioner,


    v.
    COMMISSIONER OF INTERNAL REVENUE, Respondent.
    No. 188.
    Docket 22875.

    United States Court of Appeals Second Circuit.


    Argued April 8, 1954.
    Decided 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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