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HALSTED v. COMMISSIONER

Docket No. 57648.

28 T.C. 1069 (1957)

HARBECK HALSTED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 28, 1957.

Attorney(s) appearing for the Case

Isadore Cassuto, Esq., for the petitioner.

Samuel B. Sterrett, Esq., for the respondent.

Respondent determined deficiencies in petitioner's gift tax for the calendar years 1951 and 1952 in the amounts of $663.53 and $501.46, respectively.

At issue is whether certain amounts paid by petitioner to trustees to be applied towards payment of premiums on life insurance policies held in trust qualify for the annual exclusion allowed by section 1003 (b) (3) and/or the marital deduction under section 1004 (a) (3) (E)...

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