Scott v. Commissioner
United States Tax Court
The decedent, a resident of California, acquired policies of insurance upon his life during his marriage, paying the premiums with community funds. His wife predeceased him and by her will bequeathed her interest in the policies to their two sons. There was included in her gross estate, for estate tax purposes, an amount equal to one-half of the cash surrender value of the policies as of the date of her death.
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The decedent, a resident of California, acquired policies of insurance upon his life during his marriage, paying the premiums with community funds. His wife predeceased him and by her will bequeathed her interest in the policies to their two sons. There was included in her gross estate, for estate tax purposes, an amount equal to one-half of the cash surrender value of the policies as of the date of her death. Upon the death of the decedent there was included in his gross estate, for estate tax purposes, only one-half the amount received by the beneficiaries as insurance under the policies.…
1Opinion of the Court
OPINION
AteiNS, Judge:
The respondent determined that there was a deficiency in estate tax in the amount of $10,400.81 due from the estate of Raymond R. Scott. He asserted that each of the petitioners, Donald Scott and Robert Scott, is liable for the full amount of the deficiency, as transferee and beneficiary of the estate. He also determined that the petitioner, Estate of Burt Edsall, is liable for the full amount of such deficiency, representing Burt Edsall’s personal liability as executor, under sections 6901 and 6324 of the Internal Revenue Code of 19S4, for such unpaid deficiency.…
2Cases cited4 opinions
- California Trust Company v. RiddellDistrict Court, S.D. California · 1955
- United States v. Ashby O. Stewart, of the Last Will and Testament of Mary W. Stewart, DeceasedCourt of Appeals for the Ninth Circuit · 1959
- Cranston v. MendenhallCalifornia Court of Appeal · 1960
- Burdge v. UnderwoodCalifornia Supreme Court · 1856
3Cited by6 opinions
- Estate of Silverman v. CommissionerUnited States Tax Court · 1973
- Estate of Cervin v. CommissionerUnited States Tax Court · 1994
- Estate of Coleman v. CommissionerUnited States Tax Court · 1969
- Estate of Coleman v. CommissionerUnited States Tax Court · 1969
- Estate of Silverman v. CommissionerUnited States Tax Court · 1973
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