U.S. Court of Appeals for the Second Circuit, 1954

Charles C. D. Gott v. Commissioner of Internal Revenue

U.S. Court of Appeals for the Second Circuit · Decided April 27, 1954

212 F.2d 205; 45 A.F.T.R. (P-H) 1401; 1954 U.S. App. LEXIS 4569 (Federal Reporter, Second Series)

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.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.