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PERKINS v. COMMISSIONER

Docket No. 109839.

1 T.C. 982 (1943)

JOE J. PERKINS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 20, 1943.

Attorney(s) appearing for the Case

Harry C. Weeks, Esq., for the petitioner.

Frank B. Appleman, Esq., for the respondent.

OPINION.

HILL, Judge:

The Commissioner determined a deficiency of $424.60 in the gift tax of petitioner for the taxable year 1939. The principal issue is whether the total value of a certain policy of insurance upon the life of petitioner should be included in taxable gifts when he made a gift of that policy to his wife, or whether only one-half of the value should be so included. A secondary issue is whether or not petitioner is entitled to an exclusion...

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