Raymond v. Commissioner of Internal Revenue

This appeal involves the extent of petitioner’s liability, if any, for- federal income tax, based on annuities paid to her by charitable institutions, pursuant to contract, the consideration for which was the payment of money allegedly in excess of the cost of the annuities.. Anna Raymond executed nine contracts with six charitable, educational or eleemosynary corporations, to whom she transferred property valued at $1,246,906.76 in return for payment to her of $62,500 each year of her life.

Herewith is a statement upon which the commissioner based his tax assessment which was approved by the…