Life insurance premium payments are not a gift where there is no immediate transfer of property to the nominee.

Premiums paid by an assessee on his own life insurance policies were not treated as a gift for gift-tax purposes because the payments merely discharged his contractual obligation under the policies. Although the wife was the nominee and could receive benefits on death or maturity, there was no immediate transfer of property from the assessee to the nominee. As a gift requires such an immediate transfer, the premium payments fell outside the scope of gift-tax.

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Issues: Whether insurance premia paid by the assessee on his own life insurance policies could constitute a gift liable to gift-tax.

Analysis: The assessee had merely discharged his own contractual obligation under the insurance contracts by paying the premia. Although the wife was the nominee under the policies and might ultimately receive policy benefits on death or maturity, the premium payments did not involve any immediate transfer of property from the assessee to the nominee. A gift requires such an immediate transfer, which was absent here.

Conclusion: The premium payments did not amount to a gift and could not be brought to gift-tax.

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