SELIGMANN v. COMMISSIONER

Docket No. 8403.

9 T.C. 191 (1947)

GRACE R. SELIGMANN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 15, 1947.


Attorney(s) appearing for the Case

Henry Grun, Esq., for the petitioner.

J. Marvin Kelley, Esq., for the respondent.


The Commissioner determined a deficiency of $1,803.18 in petitioner's gift tax for 1941 by adding to gifts reported amounts paid as premiums on insurance policies transferred by her husband to a trust of which she was beneficiary and as interest on loans secured by the policies. Petitioner contends that such payments were not made as gifts, but to protect her interest as beneficiary of the trust.

OPINION.

JOHNSON...

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