Haines v. Commissioner
United States Board of Tax Appeals
During the taxable year petitioner made gifts of three insurance policies to her children. The policies were single premium life insurance policies, with definite cash surrender values provided. There were no paid up insurance additions to the policies or dividends credited to the policies at the time of the gifts. Held, that the surrender values of the policies at the time of the gifts represented their values for gift tax purposes. Ernest A. Cronin,37 B.T.A. 914, followed.
1Opinion of the Court
*1015OPINION.
Black :
In this proceeding there is no dispute between the parties that taxable gifts have been made of certain insurance policies by the petitioner to her four children. These gifts were made in the taxable year and petitioner has returned them for gift tax purposes and has paid the tax thereon. The values at which the petitioner returned the gifts were the cash surrender values of the policies. The Commissioner has rejected these valuations and has computed the values in accordance with article 19 (9) of Regulations 79 (1936 Edition).
*1016Section 506 of the Revenue Act of 1932 provides:…
2Cases cited2 opinions
- Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
- Lucas v. AlexanderSupreme Court of the United States · 1929
3Cited by7 opinions
- Commissioner of Internal Revenue v. HainesCourt of Appeals for the Third Circuit · 1939
- United States v. RyersonCourt of Appeals for the Seventh Circuit · 1940
- Ryerson v. United StatesDistrict Court, N.D. Illinois · 1939
- Helvering v. BryanCourt of Appeals for the Fourth Circuit · 1940
- Haines v. CommissionerUnited States Board of Tax Appeals · 1938
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