Dorson v. Commissioner
United States Tax Court
The proceeds of policies of insurance on decedent's life which he had transferred irrevocably in trust several years prior to his death for the benefit primarily of his three children, reserving no property rights in the policies, held, not includible in his gross estate under either section 811 (c) or 811 (g) (2), Internal Revenue Code.
1Opinion of the Court
OPINION.
Smith, Judge'.
Respondent now concedes, and it is so stipulated, tha't the assignment of the policies to the trust was not a transfer made in contemplation of death. He contends in his brief, however, that it was a transfer which took effect at decedent’s death; that decedent never surrendered his control over the policies during his lifetime; that decedent’s death shifted the economic benefits under the policies; and that the proceeds are “part of decedent’s gross estate under Section 811 (c) as a transfer to take effect at his death and also under Section 811 (g) as life insurance…
2Cases cited7 opinions
- Blair v. CommissionerSupreme Court of the United States · 1937
- Freuler v. HelveringSupreme Court of the United States · 1934
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Bingham v. United StatesSupreme Court of the United States · 1935
- Industrial Trust Co. v. United StatesSupreme Court of the United States · 1935
2 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Hurd v. CommissionerUnited States Tax Court · 1947
- Ruthrauff v. CommissionerUnited States Tax Court · 1947
- Estate of Richards v. CommissionerUnited States Tax Court · 1953
- Crosley v. CommissionerUnited States Tax Court · 1966
- Estate of Jordahl v. CommissionerUnited States Tax Court · 1975
8 more not listed; retrieve them via the Exa API.