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GUGGENHEIM v. RASQUIN

No. 217.

110 F.2d 371 (1940)

GUGGENHEIM v. RASQUIN, Collector of Internal Revenue.

Circuit Court of Appeals, Second Circuit.

March 18, 1940.

Attorney(s) appearing for the Case

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Arthur L. Jacobs, Sp. Assts. to Atty. Gen., for appellant.

Paul B. Barringer, Jr., of New York City (John G. Jackson, Jr., of New York City, of counsel), for appellee.

Before SWAN, AUGUSTUS N. HAND, and PATTERSON, Circuit Judges.

PATTERSON, Circuit Judge.

The plaintiff in December 1934 took out nine life insurance policies on the single premium basis, that is to say, with the premium paid in advance in a lump sum. The policies were payable to her estate. At the time of taking them out, and as to some of the policies prior to formal issuance, the plaintiff assigned them to three children by gift. The policies insured the plaintiff's life for $1,000,000, and the cost to the plaintiff was $852...

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