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ESTATE OF PRICHARD v. COMMISSIONER

Docket No. 1352.

4 T.C. 204 (1944)

ESTATE OF JAMES STUART PRITCHARD, MYRA HELMER PRITCHARD, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 18, 1944.

Attorney(s) appearing for the Case

John O. Snook, Esq., for the petitioner.

Richard L. Greene, Esq., for the respondent.

The Commissioner determined a deficiency in the amount of $3,794.59 in the estate tax liability of petitioner. The amount in controversy is $3,525.74, and the only question at issue is whether the assignment by the decedent to his wife of certain life insurance policies constituted a bona fide sale for an adequate and full consideration, so as to prevent the inclusion of the insurance policies in the estate of the decedent upon...

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