Fisher v. Commissioner

OPINION.

OppeR, Judge-.

Section 22 (b) (1) and (2) of the Internal Revenue Code,1 which is involved here, deals in terms with three types of contract — life insurance, annuity, and endowment. Subsection (b) (1), covering amounts received under a life insurance contract paid by reason of the death of the insured, is concededly inapplicable. Cf. Grace R. Maxson Hall, 12 T. C. 419. Subsection (b) (2) refers in its first sentence to “Amounts received * * * under a life insurance * * * contract,” but excepts “amounts received as annuities” thereunder. Its second sentence prescribes the treatment of…