Estate of Lockhart v. Commissioner

*429OPINION.

Van Fossan :

The question for determination is the value for purposes of section 506 of the Revenue Act of 1932, relating to gift tax, of the insurance policies which James H. Lockhart transferred in 1935. The cited section reads: “If the gift is made in property, the value thereof at the date of the gift shall be considered the amount of the gift.”

Petitioner included the policies in his gift tax return at the cash surrender value, according to his computation. Respondent valued the policies in accordance with article 19 (9) of Regulations 79, thereby increasing the valuation.

In…