Legal Opinion

Estate of Johnson v. Commissioner

United States Tax Court

Decided August 9, 1971No. Docket No. 6306-69Published

Decedent, an employee of a State university, died in possession of two annuity contracts. Held, under sec. 2039(c)(3), I.R.C. 1954, petitioner may exclude from the gross estate that portion of the annunity proceeds attributable to contributions made by decedent's employer.

1Opinion of the Court

Estate of Leslie E. Johnson, Deceased, Ruth N. Johnson, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Johnson v. Commissioner

Docket No. 6306-69

United States Tax Court

56 T.C. 944; 1971 U.S. Tax Ct. LEXIS 83;

August 9, 1971, Filed

Decision will be entered under Rule 50.

Decedent, an employee of a State university, died in possession of two annuity contracts. Held, under sec. 2039(c)(3), I.R.C. 1954, petitioner may exclude from the gross estate that portion of the annunity proceeds attributable to contributions made by decedent's employer.

Rex B. Gilchrist and D. D.…

2Cases cited2 opinions

  1. Estate of Johnson v. CommissionerUnited States Tax Court · 1971
  2. Slayton v. CommissionerUnited States Board of Tax Appeals · 1926

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