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COMMISSIONER OF INTERNAL REVENUE v. EDWARDS

No. 8183.

135 F.2d 574 (1943)

COMMISSIONER OF INTERNAL REVENUE v. EDWARDS.

Circuit Court of Appeals, Seventh Circuit.

May 13, 1943.

Attorney(s) appearing for the Case

J. P. Wenchel and Ralph F. Staubly, Bureau of Internal Revenue, both of Washington, D. C., and Samuel O. Clark, Jr., Sewall Key, and L. W. Post, Sp. Asst. Attys. Gen., for petitioner.

Kenneth M. Fiske, Metellus Thomson, Jr., and John H. Letsinger, all of Chicago, Ill., for respondent.

Before EVANS and MINTON, Circuit Judges, and LINDLEY, District Judge.

LINDLEY, District Judge.

Petitioner seeks to reverse the Tax Court's determination of the value of eight annuity contracts, at the time respondent transferred them by gift. The policies were issued in 1934 and 1935; the gifts executed June 11, 1936. Respondent reported the transaction, and the commissioner, believing the value placed upon the contracts too low, increased it and levied a deficiency gift tax. Upon review, the court fixed the value upon the basis of...

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