United States Tax Court January 31, 1944, Docket No. 112002 (Haverty Realty & Inv. Co. v. Commissioner)

lead-opinion

OPINION.

Disney, Judge:

Are the net proceeds of the two life insurance polices transferred to the petitioner to be excluded from petitioner’s gross income? In the deficiency notice reliance is placed upon section 22 (a) and 22 (b) (2) of the Internal Revenue Code. Upon brief, the respondent bases his position only upon section 22 (b) (1), (2).