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GUGGENHEIM v. RASQUIN

No. 92.

312 U.S. 254 (1941)

GUGGENHEIM v. RASQUIN, ADMINISTRATRIX.

Supreme Court of United States.

Decided February 3, 1941.

Attorney(s) appearing for the Case

Mr. John G. Jackson, Jr., with whom Mr. Paul B. Barringer, Jr. was on the brief, for petitioner.

Mr. J. Louis Monarch, with whom Solicitor General Biddle, Assistant Attorney General Clark, and Messrs. Sewall Key, Arnold Raum, and Joseph M. Jones were on the brief, for respondent.

Messrs. J. Merrill Wright and David R. Shelton filed a brief on behalf of Martha F. Mason, as amicus curiae, urging reversal.

MR. JUSTICE DOUGLAS delivered the opinion of the Court.

It is provided in the Revenue Act of 1932 (47 Stat. 169, 248) that for gift-tax purposes the amount of a gift of property shall be "the value thereof at the date of the gift." § 506. This controversy involves the question of whether such "value" in case of single-premium life insurance policies, which are irrevocably assigned simultaneously with issuance, is cost to the donor or cash-surrender value of the...

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