Estate of Dimen v. Commissioner
United States Tax Court
Decedent was sole shareholder of a corporation which owned a split dollar life insurance policy on decedent's life. The proceeds were payable to the corporation to the extent of cash surrender value with the remaining portion payable to decedent's daughter.
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Decedent was sole shareholder of a corporation which owned a split dollar life insurance policy on decedent's life. The proceeds were payable to the corporation to the extent of cash surrender value with the remaining portion payable to decedent's daughter. Held, the corporation, and thus decedent, possessed sufficient incidents of ownership in the policy, within the meaning of sec. 20.2042-1(c)(6), Estate Tax Regs., to cause the proceeds of the policy to be included in decedent's gross estate.
1Opinion of the Court
Estate of Alfred Dimen, Philip Wolitzer, Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Dimen v. Commissioner
Docket No. 1985-76
United States Tax Court
72 T.C. 198; 1979 U.S. Tax Ct. LEXIS 131;
April 24, 1979, Filed
Decision will be entered under Rule 155.
Decedent was sole shareholder of a corporation which owned a split dollar life insurance policy on decedent's life. The proceeds were payable to the corporation to the extent of cash surrender value with the remaining portion payable to decedent's daughter. Held, the corporation, and thus decedent, possessed…
2Cases cited9 opinions
- United States v. Rhode Island Hospital Trust CompanyCourt of Appeals for the First Circuit · 1966
- Estate of James H. Lumpkin, Jr., Deceased. Christine T. Hamilton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Schwager v. CommissionerUnited States Tax Court · 1975
- Estate of Lumpkin v. CommissionerUnited States Tax Court · 1971
- Karagheusian v. CommissionerUnited States Tax Court · 1955
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