Cronin v. Commissioner
United States Board of Tax Appeals
In 1933 the petitioner took out two single premium insurance policies on his life, naming his daughter as beneficiary. On December 30, 1935, he irrevocably named his daughter or her executors or administrators as beneficiaries and relinquished all rights, privileges, and incidents of ownership in the policies.
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In 1933 the petitioner took out two single premium insurance policies on his life, naming his daughter as beneficiary. On December 30, 1935, he irrevocably named his daughter or her executors or administrators as beneficiaries and relinquished all rights, privileges, and incidents of ownership in the policies. He made a gift tax return for 1935, reporting therein as the value of the policies their cash surrender value on December 30, 1935. held, that the value of cash policy on December 30, 1935, for gift tax purposes was the cash surrender value on that date.
1Opinion of the Court
OPINION.
Smith :
This proceeding is for the redetermination of a deficiency in gift tax for 1935 in the amount of $237.88.
*915Petitioner alleges that the respondent erred in the determination of the deficiency as follows:(a) The Commissioner of Internal Revenue was in error in determining that the value of a transfer by gift of property, to-wit, $25,000.00, Provident Mutual Life Insurance Company Single Premium Life Insurance Policy No. 715768, irrevocably assigned to donor’s daughter on December 30, 1935, was its cost at time of such assignment, to-wit, $17,923.25, and not as petitioner claims and…
2Cases cited8 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
- Koshland v. HelveringSupreme Court of the United States · 1936
- Reinecke v. SpaldingSupreme Court of the United States · 1930
3 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Ryerson v. United StatesDistrict Court, N.D. Illinois · 1939
- Helvering v. BryanCourt of Appeals for the Fourth Circuit · 1940
- Cronin v. CommissionerUnited States Board of Tax Appeals · 1938
- Haines v. CommissionerUnited States Board of Tax Appeals · 1938
- Kirk v. CommissionerUnited States Board of Tax Appeals · 1939
1 more not listed; retrieve them via the Exa API.