Legal Opinion

Estate of Headrick v. Comm'r

United States Tax Court

Decided August 7, 1989No. Docket No. 21659-86Published

D, a decedent, established an irrevocable inter vivos trust with B, a bank, as trustee. The trust agreement drafted by D authorized, but did not require, B to invest the trust principal in life insurance policies. B exercised independent discretion in acquiring a whole life insurance policy on D's life. D contributed cash annually to the trust in amounts sufficient to meet the trust's cumulative monthly premium obligations.

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D, a decedent, established an irrevocable inter vivos trust with B, a bank, as trustee. The trust agreement drafted by D authorized, but did not require, B to invest the trust principal in life insurance policies. B exercised independent discretion in acquiring a whole life insurance policy on D's life. D contributed cash annually to the trust in amounts sufficient to meet the trust's cumulative monthly premium obligations. D died in an automobile accident within three years of the trust's purchase of the policy. Held, D never possessed "incidents of ownership" in the life insurance policy…

1Opinion of the Court

Estate of Eddie L. Headrick, Deceased, Cleveland Bank & Trust Company and Charles L. Almond, Executors, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Headrick v. Comm'r

Docket No. 21659-86

United States Tax Court

93 T.C. 171; 1989 U.S. Tax Ct. LEXIS 114; 93 T.C. No. 18;

August 7, 1989; As corrected August 7, 1989, Filed

Decision will be entered under Rule 155.

D, a decedent, established an irrevocable inter vivos trust with B, a bank, as trustee. The trust agreement drafted by D authorized, but did not require, B to invest the trust principal in life insurance policies. B…

2Cases cited9 opinions

  1. The Detroit Bank & Trust Company, of the Estate of Fred W. Ritter, Deceased v. United StatesCourt of Appeals for the Sixth Circuit · 1972
  2. Bel v. United StatesCourt of Appeals for the Fifth Circuit · 1971
  3. Estate of Kurihara v. CommissionerUnited States Tax Court · 1984
  4. Estate of Leder v. CommissionerUnited States Tax Court · 1987
  5. Grover H. Hope, of the Estate of Beverly J. Hope, Deceased v. United States of America, Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1982

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