Phil L. Zimmermann v. Commissioner of Internal Revenue

VAN OOSTERHOUT, Circuit Judge.

Taxpayer, Zimmermann, has petitioned this court to review the decision of the Tax Court, reported at 25 T.C. 233, determining that taxpayer realized $2,955.03 in taxable income in 1951 through the receipt of proceeds from two contracts issued by Massachusetts Mutual Life Insurance Company, hereinafter called insurance company. Taxpayer received from the insurance company in 1951 $3,000 under Option A, hereinafter described. Interest upon the unpaid balance of the proceeds of the two contracts was credited to the taxpayer for the year 1951 in the amount of…