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FRIEDMAN v. COMMISSIONER

Docket No. 2758-62.

41 T.C. 428 (1963)

S. M. FRIEDMAN AND ESTHER G. FRIEDMAN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 31, 1963.

Attorney(s) appearing for the Case

Philip J. Wolf and Jerry M. Hamovit, for the petitioners.

Buckley D. Sowards, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the calendar years 1957 and 1958 in the respective amounts of $4,912.44 and $16,366.23.

The issue for decision is whether petitioners realized taxable income in the amounts by which the values of endowment insurance policies transferred by S. M. Friedman to charitable organizations exceeded his bases in such policies.

All of the facts have been...

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