Commissioner of Internal Revenue v. Powers

SWEENEY, District Judge.

This case is before us on the petition of the Commissioner of Internal Revenue to review a decision of the Board of Tax Appeals, entered January 9, 1939, in which *210that Board ruled that there was no deficiency in the gift tax paid by the respondent for the year 1935.

In late November and early December, 1935, the respondent Madeleine D. Powers purchased six single premium policies of insurance as follows:

Company and policy number Date of issue of policy Name of insured Face amount of policy Amount of single premium paid Type of policy

The Fidelity Mutual Life Ins. Co.,…