Commissioner of Internal Revenue v. Edwards

LINDLEY, District Judge.

Petitioner seeks to reverse the Tax Court’s determination of the value of eight annuity contracts, at the time respondent transferred them by gift. The policies were issued in 1934 and 1935; the gifts executed June 11, 1936. Respondent reported the transaction, and the commissioner, believing the value placed upon the contracts too low, increased it and levied a deficiency gift tax. Upon review, the court fixed the value upon the basis of the “interpolated terminal reserve at the date of the gift.” Petitioner contends that the value should have been ascertained by…