Rosalind F. Kaufman v. United States

CLARK, Circuit Judge:

The facts of this gift tax case are undisputed. It is the effect upon these facts of the legal emanations flowing from Commissioner of Int. Rev. v. Chase Manhattan Bank, 259 F.2d 231 (5th Cir. 1958), which this appeal must settle.

Taxpayer, Rosalind Kaufman, and her deceased husband were residents of Louisiana (a community property state) until the time of her spouse’s death on July 24, 1967. During their marriage, community funds were used to purchase certain life insurance policies on Mr. Kaufman. The beneficiaries were revoc-ably designated by Mr. Kaufman at the time he…