Kirk v. Commissioner
United States Board of Tax Appeals
During the years 1933 and 1934 C. Henderson Supplee took out insurance policies upon his own life, irrevocably naming his wife, Flora D. Supplee, the beneficiary, if living at the date of his death. In each instance his wife paid one-half of the premium. From the date of issuance the wife had the right to surrender the policies and receive the cash surrender value.
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During the years 1933 and 1934 C. Henderson Supplee took out insurance policies upon his own life, irrevocably naming his wife, Flora D. Supplee, the beneficiary, if living at the date of his death. In each instance his wife paid one-half of the premium. From the date of issuance the wife had the right to surrender the policies and receive the cash surrender value. The value of the gifts was reported as one-half of the cancellation value of each policy at the date of issuance. The respondent contends that the value of the gift in each case was one-half of the premium paid. Held, that the…
1Opinion of the Court
ELIZABETH S. KIRK, MARIE SUPPLEE DICKSON AND HENDERSON SUPPLEE, JR., EXECUTRICES AND EXECUTOR OF THE WILL OF C. HENDERSON SUPPLEE, DECEASED, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Kirk v. Commissioner
Docket No. 89363.
United States Board of Tax Appeals
39 B.T.A. 902; 1939 BTA LEXIS 960;
May 18, 1939, Promulgated
During the years 1933 and 1934 C. Henderson Supplee took out insurance policies upon his own life, irrevocably naming his wife, Flora D. Supplee, the beneficiary, if living at the date of his death. In each instance his wife paid one-half of the premium. From the…
2Cases cited2 opinions
- Cronin v. CommissionerUnited States Board of Tax Appeals · 1938
- Kirk v. CommissionerUnited States Board of Tax Appeals · 1939