Legal Opinion

Lockhart v. Commissioner

United States Board of Tax Appeals

Decided February 25, 1942No. Docket No. 92375Published

During the year 1935 original petitioner made gifts of certain insurance policies, some of which were fully paid up and some of which were not paid up. He included them in his gift tax return at their cash surrender value. Held, replacement cost is the proper criterion of value of the policies for gift tax purposes. Guggenheim v. Rasquin,312 U.S. 254; United States v. Ryerson,312 U.S. 260; Houston v. Commissioner, 124 Fed.(2d) 518; Margaret R. Phipps,43 B.T.A. 790.

1Opinion of the Court

ESTATE OF JAMES H. LOCKHART, DECEASED, CHARLES LOCKHART, GEORGE D. LOCKHART, JAMES H. LOCKHART, JR. AND JOHN L. WALKER, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Lockhart v. Commissioner

Docket No. 92375.

United States Board of Tax Appeals

46 B.T.A. 426; 1942 BTA LEXIS 865;

February 25, 1942, Promulgated

During the year 1935 original petitioner made gifts of certain insurance policies, some of which were fully paid up and some of which were not paid up. He included them in his gift tax return at their cash surrender value. Held, replacement cost is the proper…

2Cases cited4 opinions

  1. United States v. RyersonSupreme Court of the United States · 1941
  2. Guggenheim v. RasquinSupreme Court of the United States · 1941
  3. Phipps v. CommissionerUnited States Board of Tax Appeals · 1941
  4. Estate of Lockhart v. CommissionerUnited States Board of Tax Appeals · 1942

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