Commissioner of Corporations & Taxation v. Kellaway

The taxpayer, an inhabitant of this Commonwealth, has been an employee of a corporation since 1927. In 1940 his employer, “in appreciation of and as a reward for his faithful services,” and for his benefit, purchased for him an “annuity policy” by which an insurance company agreed to pay him $544.05 on December 20, 1941, and a like sum each year thereafter during his life. The taxpayer took no part in obtaining the policy except to sign the application as he was required to do. The employer *193paid to the insurance company the single premium of $13,500. The policy provided that if the taxpayer…