BURR v. COMMISSIONER OF INTERNAL REVENUE

No. 133, Docket 19992.

156 F.2d 871 (1946)

BURR et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

July 17, 1946.


Attorney(s) appearing for the Case

Alexander Halpern, of New York City, for petitioners.

L. W. Post, Sp. Asst. to the Atty. Gen. (Sewall Key, Acting Asst. Atty. Gen., and Helen R. Carloss, Sp. Asst. to the Atty. Gen., on the brief), for respondent.

Before SWAN, CLARK, and FRANK, Circuit Judges.


CLARK, Circuit Judge.

This is a petition by executors of a decedent's estate for review of a decision of the Tax Court, holding taxable under § 811(c) of the Internal Revenue Code, 26 U.S.C.A. Int.Rev.Code, § 811(c), three life insurance policies which the decedent took out in connection with an annuity and thereafter assigned irrevocably to the beneficiaries. The only real issue concerns the effect of the assignment under the applicable statute which makes...

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