Commissioner of Internal Revenue v. Powers

The statute does not define “value”, but merely provides that if the gift is made in property “the value thereof at the date of the gift shall be considered the amount of the gift”. It is not clear to me that the cash surrender value test stated in Article 2 (5) of Regulations 79 (1932 Ed.) is invalid as in conflict with the statute. Nor is it clear to me that the specific provision in Article 2(5) (1932 Ed.) dealing with this particular species of property is inconsistent with the general provisions of Article 19(1) of the same edition of the Regulations. But the provisions of the 1932…