Legal Opinion

Commissioner of Internal Revenue v. Haines

Court of Appeals for the Third Circuit

Decided June 14, 1939No. 6912PublishedCited by 12 opinions

1Opinion of the Court

DAVIS, Circuit Judge. .

In 1934, Mary H. Haines, respondent, paid certain insurance companies $313,419 for three “single premium” life Insurance policies, naming as beneficiaries her four children, Isabella H. Miller, Margaret W. Haines, Robert B. Haines and Charles H. Haines. The policies so purchased had a cash surrender value of $289,324 and a face value of $350,000.

As the- respondent did not retain “any of the legal incidents of ownership” to the policies, she filed a gift tax return for that year in which she included the above mentioned policies at their cash surrender value. The…

2Cases cited2 opinions

  1. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  2. Haines v. CommissionerUnited States Board of Tax Appeals · 1938

3Cited by12 opinions

  1. Guggenheim v. RasquinSupreme Court of the United States · 1941
  2. United States v. RyersonCourt of Appeals for the Seventh Circuit · 1940
  3. Helvering v. CroninCourt of Appeals for the Eighth Circuit · 1939
  4. Guggenheim v. RasquinCourt of Appeals for the Second Circuit · 1940
  5. Commissioner of Internal Revenue v. PowersCourt of Appeals for the First Circuit · 1940

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