SIBLEY, Circuit Judge.
The taxpayer, Mrs. Dora Roberts, had in 1938 and the tax years 1939, 1940 and 1941, a widowed daughter, Mrs. Garrett, who had an adult son, Horace Garrett, and another widowed daughter, Mrs. Canter, who had two minor sons, Roger Ellwood Canter and Curtis Kendal Canter, aged nine and twelve years. During 1938 she applied to Aetna Life Insurance Company for a "guaranteed endowment annuity" policy for the benefit of each grandchild, and to the...
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