Charles C. D. Gott v. Commissioner of Internal Revenue
This text of 212 F.2d 205 (Charles C. D. Gott v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
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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212 F.2d 205, 45 A.F.T.R. (P-H) 1401, 1954 U.S. App. LEXIS 4569, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charles-c-d-gott-v-commissioner-of-internal-revenu-ca2-1954.