Estate of Cavenaugh v. Commissioner

EDITH H. JONES, Circuit Judge:

The Estate of Herbert Cavenaugh invested considerable intellectual and creative resources to minimize its tax liability. It excluded the value of property Herbert re*599ceived upon the death of his first wife Mary Jane because of the technical possibility that he might not be entitled to all of the income from the property, and it excluded half of the life insurance proceeds paid on his death to the estate, asserting that Texas law still recognized Mary Jane’s community interest in the proceeds. Unimpressed by the estate’s acumen, the Commissioner of Internal Revenue…