Powers v. Commissioner, 312 U.S. 259 (1941)

Powers v. Commissioner

No. 486

Argued January 7, 1941
Decided February 3, 1941
312 U.S. 259

CERTIORARI TO THE CIRCUIT COURT OF APPEALS

FOR THE FIRST CIRCUIT

Syllabus

Determination of the criterion of "value" for the purposes of the gift tax under the Revenue Act of 1932 is a question of law, and a decision of the Board of Tax Appeals that, in the case of single premium policies of life insurance, irrevocably assigned as gifts shortly after issuance, the value of the gifts was the cash surrender value of the policies, was properly reversed by the Circuit Court of Appeals as "not in accordance with law." Guggenheim v. Rasquin, ante, p. 254. P. 260.

115 F.2d 209 affirmed.

Certiorari, 311 U.S. 640, to review the reversal of a decision of the Board of Tax Appeals setting aside a determination of a deficiency in a gift tax.