Commissioner of Corporations & Taxation v. Hale

The taxpayer, a former employee of the Boston Edison Company, hereinafter called the employer, entered into a written contract with the employer by which the employer agreed upon the employee’s retirement tó pay him a certain amount monthly. This contract was designated “Service Annuity Contract — Series A.” Payments according to said contract were made from the time of his retirement in February, 1931, until June 1, 1936. The source of these payments was a trust fund which the employer maintained at a Boston bank. The employer on May 1, 1936, entered into a group annuity contract with an…