Houston v. Commissioner of Internal Revenue

The taxpayer in 1934 made a gift of five life insurance policies on his own life. The policies had been issued prior to 1914 on the twenty-payment-life plan and at the time when the taxpayer’s gift was made had become fully paid up. The taxpayer contends that the value of the policies, upon which the gift tax is to be estimated, should be the cash surrender value they bore at the date of the transfer. The Commissioner’s contention is that the value should be the replacement cost computed by using the amounts the companies would have charged a person of the taxpayer’s attained age for single…