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HELVERING v. BRYAN

No. 4582.

109 F.2d 430 (1940)

HELVERING, Com'r of Internal Revenue, v. BRYAN.

Circuit Court of Appeals, Fourth Circuit.

January 31, 1940.

Attorney(s) appearing for the Case

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

R. E. Cabell, of Richmond, Va., for respondent.

Before PARKER, SOPER, and DOBIE, Circuit Judges.

SOPER, Circuit Judge.

Gift taxes on the value of twenty-four life insurance policies issued on the life of the taxpayer and included in gifts made by him during the calendar year 1935, are the subject of this review. The taxpayer reported a valuation of $38,873.94, based on the net cash surrender value of the policies on the date of gift, and the Board of Tax Appeals approved the valuation. The Commissioner of Internal Revenue proposed a valuation of $49,658.69, which...

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