Estate of Kurihara v. Commissioner
United States Tax Court
Decedent established a life insurance trust. The trustee applied for the policy on decedent's life and paid the initial premium with a check of decedent's in the exact amount of the premium. Decedent died 3 months later. Held, the trustee purchased the policy in his capacity as decedent's agent rather than as an independent trustee.
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Decedent established a life insurance trust. The trustee applied for the policy on decedent's life and paid the initial premium with a check of decedent's in the exact amount of the premium. Decedent died 3 months later. Held, the trustee purchased the policy in his capacity as decedent's agent rather than as an independent trustee. Held, further, the policy proceeds are includable in decedent's estate under sec. 2035, I.R.C. 1954. Estate of Coleman v. Commissioner, 52 T.C. 921 (1969), explained and distinguished.
1Opinion of the Court
Estate of Tetsuo Kurihara, Deceased, Eleanore Kurihara, Administratrix, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Kurihara v. Commissioner
Docket No. 10402-81
United States Tax Court
82 T.C. 51; 1984 U.S. Tax Ct. LEXIS 127; 82 T.C. No. 4;
January 5, 1984, Filed
Decision will be entered under Rule 155.
Decedent established a life insurance trust. The trustee applied for the policy on decedent's life and paid the initial premium with a check of decedent's in the exact amount of the premium. Decedent died 3 months later. Held, the trustee purchased the policy in his capacity…
Also in this document: Concurrence.
2Cases cited15 opinions
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Hicks v. CommissionerUnited States Tax Court · 1966
- United States v. Rhode Island Hospital Trust CompanyCourt of Appeals for the First Circuit · 1966
- Estate of Coleman v. CommissionerUnited States Tax Court · 1969
- The Detroit Bank & Trust Company, of the Estate of Fred W. Ritter, Deceased v. United StatesCourt of Appeals for the Sixth Circuit · 1972
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