Beattie v. COMMISSIONER OF INTERNAL REVENUE

MILLER, Circuit Judge.

The petitioner, Elizabeth L. Beattie, seeks a review of an order of the Tax Court adjudging a deficiency of $284.06 in the petitioner’s income tax for the calendar year 1941.

On January 1, 1927, Edward Burkett Miller and his wife, who is now Elizabeth L. Beattie, the petitioner herein, conveyed to Mount Union College of Alliance, Ohio, property having a net valuation of $265,-000, and in exchange therefor received a Survivorship Life Annuity Bond under which the College agreed to pay to Miller during his lifetime $1500 per month beginning February 1, 1927, and after his…