Fisher v. Commissioner
United States Board of Tax Appeals
1. The value for gift tax purposes of single premium life insurance policies on the donor's life which the donor transferred as a gift in trust, held, the cost of the policies to the donor. Guggenheim v. Rasquin,312 U.S. 254. 2. In 1937 petitioner conveyed to a trustee, irrevocably, certain bonds for the benefit of her grandchildren.
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1. The value for gift tax purposes of single premium life insurance policies on the donor's life which the donor transferred as a gift in trust, held, the cost of the policies to the donor. Guggenheim v. Rasquin,312 U.S. 254. 2. In 1937 petitioner conveyed to a trustee, irrevocably, certain bonds for the benefit of her grandchildren. The net income of the trust was to be distributed annually on December 20 to the beneficiaries (or to their parents or guardians until they were 21 years of age) until they attained the age of 25 years, when their proportional interests in the trust corpus were…
1Opinion of the Court
*961OPINION.
Smith :
The first question presented by this proceeding is whether the two paid-up single premium life insurance policies on the life of the donor should be valued for gift tax purposes at the cost of the policies to the donor, as determined by the respondent, or at their cash surrender values at the date of the gift, as contended by the petitioner. This issue is decided in favor of the respondent upon authority of Guggenheim v. Rasquin, 312 U. S. 254.
The second question is what exclusions, if any, the petitioner is entitled to in respect of the trust which she created for the benefit…
2Cases cited4 opinions
- United States v. PelzerSupreme Court of the United States · 1941
- Guggenheim v. RasquinSupreme Court of the United States · 1941
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Ryerson v. United StatesSupreme Court of the United States · 1941
3Cited by14 opinions
- Estate of Sparling v. CommissionerUnited States Tax Court · 1973
- Hutchinson v. CommissionerUnited States Tax Court · 1967
- Quatman v. CommissionerUnited States Tax Court · 1970
- Estate of Kolker v. CommissionerUnited States Tax Court · 1983
- Clark v. CommissionerUnited States Tax Court · 1975
9 more not listed; retrieve them via the Exa API.