Harris v. Commissioner
United States Tax Court
1. Gift Tax -- Nonresident Alien -- Bank Deposits. -- Money on deposit in American banks is not exempt or excluded from gift tax as property without the United States on the theory that section 863 (b) of the estate tax chapter is to be read into the gift tax chapter. 2. Gift Tax -- Premiums on Insurance. -- Payments of premiums by wife on policy belonging exclusively to husband were not precluded from being gift on ground that wife had an interest in the policies as…
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1. Gift Tax -- Nonresident Alien -- Bank Deposits. -- Money on deposit in American banks is not exempt or excluded from gift tax as property without the United States on the theory that section 863 (b) of the estate tax chapter is to be read into the gift tax chapter. 2. Gift Tax -- Premiums on Insurance. -- Payments of premiums by wife on policy belonging exclusively to husband were not precluded from being gift on ground that wife had an interest in the policies as husband's heir. 3. Gift Tax -- Settlement at Divorce. -- Payments by wife pursuant to property settlement adopted in decree of…
1Opinion of the Court
Cornelia Harris, Petitioner, v. Commissioner of Internal Revenue, Respondent
Harris v. Commissioner
Docket No. 11616
United States Tax Court
10 T.C. 741; 1948 U.S. Tax Ct. LEXIS 202;
April 30, 1948, Promulgated
Decision will be entered under Rule 50.
1. Gift Tax -- Nonresident Alien -- Bank Deposits. -- Money on deposit in American banks is not exempt or excluded from gift tax as property without the United States on the theory that section 863 (b) of the estate tax chapter is to be read into the gift tax chapter.
2. Gift Tax -- Premiums on Insurance. -- Payments of premiums by wife on policy…
2Cases cited7 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Merrill v. FahsSupreme Court of the United States · 1945
- Chapman v. CommissionerUnited States Tax Court · 1947
- Estate of Barnard v. CommissionerUnited States Tax Court · 1947
2 more not listed; retrieve them via the Exa API.