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FLICK'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE

No. 12160.

166 F.2d 733 (1948)

FLICK'S ESTATE v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

As Corrected on Denial of Rehearing April 16, 1948.

Attorney(s) appearing for the Case

Albert R. Connelly, and Cravath, Swaine & Moore, all of New York City, for petitioners.

Charles Oliphant, Chief Counsel, Bureau of Internal Revenue, and Charles E. Lowery, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., Theron L. Caudle, Asst. Atty. Gen., and Sewall Key, George A. Stinson, Robert N. Anderson and L. W. Post, Sp. Assts. to the Atty. Gen., for respondent.

Before SIBLEY, HOLMES, and WALLER, Circuit Judges.

WALLER, Circuit Judge.

On December 9, 1935, R. Jay Flick created an insurance trust with Bankers Trust Company, a New York corporation, and Robert I. Ingalls, Jr., a resident of Alabama, as trustees, to which trust the decedent on that date made complete, absolute, and irrevocable assignments of six paid-up life insurance policies. Data in reference to these policies may be synopsized as follows:

                                        When     Face  ...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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