HELVERING v. CRONIN

No. 11420.

106 F.2d 907 (1939)

HELVERING, Commissioner of Internal Revenue, v. CRONIN.

Circuit Court of Appeals, Eighth Circuit.

November 1, 1939.


Attorney(s) appearing for the Case

John J. Pringle, Jr., Sp. Asst. to Atty. Gen. (Sewall Key, Sp. Asst. to Atty. Gen., on the brief), for petitioner.

Roy K. Dietrich, of Kansas City, Mo. (Alfred N. Gossett and Frank E. Tyler, both of Kansas City, Mo., on the brief), for respondent.

Before THOMAS and VAN VALKENBURGH, Circuit Judges, and DEWEY, District Judge.


THOMAS, Circuit Judge.

This is a petition to review a decision of the United States Board of Tax Appeals. 37 B. T. A. 914. The order of the Board redetermined the gift taxes imposed upon the taxpayer for the year 1935. The question presented is, What is the value within the meaning of the Revenue Act of 1932, c. 209, 47 Stat. 169, for gift tax purposes of a single premium life insurance policy. Is the value the cost of such a policy on the date of the gift or its...

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