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POWERS v. COMMISSIONER

No. 486.

312 U.S. 259 (1941)

POWERS v. COMMISSIONER OF INTERNAL REVENUE.

Supreme Court of United States.

Decided February 3, 1941.

Attorney(s) appearing for the Case

Mr. Ralph G. Boyd 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.

MR. JUSTICE DOUGLAS delivered the opinion of the Court.

The issue in this case is the same as that in Guggenheim v. Rasquin, ante, p. 254. Petitioner in November and December, 1935, purchased single-premium policies of insurance on her own life and late in December, 1935, irrevocably assigned them as gifts. The Commissioner determined a deficiency, claiming that the value of the policies for gift-tax purposes was the cost of duplicating them at the dates...

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