Stoumen v. Commissioner
United States Tax Court
Abraham Stoumen died a suicide in 1946. In 1953 this Court held that Abraham owed income taxes and additions to tax for the years 1943, 1944, and 1945, in an amount exceeding $ 270,000. At his death Abraham had assets of more than $ 338,000, which included life insurance proceeds of more than $ 113,000. His liabilities, including the taxes determined in 1953, were over $ 297,000. Abraham retained until his death all incidents of ownership of the insurance policies, including…
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Abraham Stoumen died a suicide in 1946. In 1953 this Court held that Abraham owed income taxes and additions to tax for the years 1943, 1944, and 1945, in an amount exceeding $ 270,000. At his death Abraham had assets of more than $ 338,000, which included life insurance proceeds of more than $ 113,000. His liabilities, including the taxes determined in 1953, were over $ 297,000. Abraham retained until his death all incidents of ownership of the insurance policies, including the right to change the beneficiaries of the policies. Petitioner Mary Stoumen, as executrix of Abraham's estate,…
1Opinion of the Court
Teetjens, Judge:
The Commissioner determined that the petitioners are liable as transferees of the assets of Abraham L. Stoumen, deceased, for deficiencies in income taxes and additions to the taxes, due from the Estate of Abraham L. Stoumen, deceased, as follows:
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There are two issues for decision: (1) Whether the petitioners, as the beneficiaries of certain insurance policies on the life of Abraham L. Stoumen, deceased, are liable as transferees for his unpaid income taxes, additions to the tax, and interest thereon, for the years 1943, 1944, and 1945, to the extent of the…
2Cases cited15 opinions
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- United States v. International Building Co.Supreme Court of the United States · 1953
- Lawrence v. CommissionerUnited States Tax Court · 1957
- Scott v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1941
- Ruth Halle Rowen, Ethel F. Halle, and Edward Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
10 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Commissioner v. SternSupreme Court of the United States · 1958
- Sidney Kreps v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965
- Estate of Glass v. CommissionerUnited States Tax Court · 1970
- Bowlin v. Comm'rUnited States Tax Court · 1958
- Stoumen v. CommissionerCourt of Appeals for the Third Circuit · 1958
9 more not listed; retrieve them via the Exa API.