Phipps v. Commissioner
United States Board of Tax Appeals
In 1937 petitioner irrevocably assigned as gifts a single premium endowment insurance policy issued to her on her own life and two annual premium ordinary life insurance policies also issued to her on her own life. At the date of gift only the first annual premiums had been paid on the two ordinary life policies, and such policies had no cash surrender value until three years' full premiums had been paid.
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In 1937 petitioner irrevocably assigned as gifts a single premium endowment insurance policy issued to her on her own life and two annual premium ordinary life insurance policies also issued to her on her own life. At the date of gift only the first annual premiums had been paid on the two ordinary life policies, and such policies had no cash surrender value until three years' full premiums had been paid. Held, that the proper criterion for the valuation of the three policies for gift tax purposes was the cost of duplicating the policies at the date of gift rather than the cash surrender…
1Opinion of the Court
MARGARET R. PHIPPS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Phipps v. Commissioner
Docket No. 96471.
United States Board of Tax Appeals
43 B.T.A. 790; 1941 BTA LEXIS 1453;
February 28, 1941, Promulgated
In 1937 petitioner irrevocably assigned as gifts a single premium endowment insurance policy issued to her on her own life and two annual premium ordinary life insurance policies also issued to her on her own life. At the date of gift only the first annual premiums had been paid on the two ordinary life policies, and such policies had no cash surrender value until three years'…
2Cases cited5 opinions
- United States v. RyersonSupreme Court of the United States · 1941
- Guggenheim v. RasquinSupreme Court of the United States · 1941
- Powers v. CommissionerSupreme Court of the United States · 1941
- Thompson v. CommissionerUnited States Board of Tax Appeals · 1940
- Phipps v. CommissionerUnited States Board of Tax Appeals · 1941