GOODMAN v. COMMISSIONER OF INTERNAL REVENUE

No. 64.

156 F.2d 218 (1946)

GOODMAN v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

June 20, 1946.


Attorney(s) appearing for the Case

A. Harding Paul and R. H. Yeatman, Jr., both of Washington, D. C., and Raymond M. White, of New York City, for petitioner.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, A. F. Prescott, and Melva M. Graney, Sp. Assts. to the Atty. Gen., for respondent.

Before SWAN, CLARK, and WOODBURY, Circuit Judges.


WOODBURY, Circuit Judge.

The sole question presented by this petition for review of a decision of the Tax Court of the United States is the value for gift tax purposes of certain policies of insurance taken out by the taxpayer on the life of her husband. For present purposes the facts may be briefly summarized as follows:

On December 19, 1930, the taxpayer created a trust, transferring to the trustee certain securities, and also five ordinary life, annual...

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