In 1932 respondent taxpayer irrevocably transferred to a trustee six insurance policies on his own life of a total face value of $500,000. The immediate beneficiaries named in the trust agreement are the taxpayer's wife and son.
In 1936 and 1937 the taxpayer paid premiums on the policies in the amounts of $12,192.50 and $12,109, respectively, and reported gifts to his wife and son each of one...
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