Manne v. Commissioner of Internal Revenue

RIDDICK, Circuit Judge.

The question is whether sums paid to the taxpayer under nine contracts with insurance companies were received as annuities under annuity or endowment contracts within the meaning of section 22(b) (2) of the Internal Revenue Code, 26 U.S. C.A. Int.Rev.Code, § 22(b) (2). The statute and regulations involved are printed in the margin.1

Each of the contracts in question was purchased by the taxpayer for a lump sum and was entitled “Annuity Contract.” In each contract the insurance company agreed to make periodical payments of a stated sum to the taxpayer during his life, the…