Crosley v. Commissioner
United States Tax Court
Decedent was insured under 25 different life insurance policies. In 1934 he executed an instrument in which he purported to transfer all of these policies to an irrevocable inter vivos trust and thereby divest himself of all right, title, and interest in them.
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Decedent was insured under 25 different life insurance policies. In 1934 he executed an instrument in which he purported to transfer all of these policies to an irrevocable inter vivos trust and thereby divest himself of all right, title, and interest in them. The power of the independent trustees was limited to entering into agreements with the issuing companies with respect to the distribution of the policy proceeds and all matters with respect to the rights of any person under the policies; the designation of beneficiaries of the policies was limited to a small group of members of…
1Opinion of the Court
Hoyt, Judge:
Respondent determined a deficiency of $1,021,062.30 in the estate tax of the Estate of Powel Crosley, Jr., deceased. The parties having settled by stipulation an issue involving the valuation of certain real property, the only question for our decision is whether the proceeds of 25 insurance policies covering the life of Powel Crosley, Jr., are includable in his estate under the provisions of section 2042, 2036, or 2038 of the Internal Revenue Code of 1954.1
PINDINGS OP PACT
Powel Crosley, Jr. (hereinafter referred to as Crosley or as decedent) , died on March 28, 1961, and his will…
2Cases cited22 opinions
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Edwards v. SlocumSupreme Court of the United States · 1924
- Commissioner v. Estate of NoelSupreme Court of the United States · 1965
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3Cited by7 opinions
- Fruehauf v. CommissionerUnited States Tax Court · 1968
- Estate of Gorby v. CommissionerUnited States Tax Court · 1969
- Estate of Bartlett v. CommissionerUnited States Tax Court · 1970
- Crosley v. CommissionerUnited States Tax Court · 1966
- Estate of Bartlett v. CommissionerUnited States Tax Court · 1970
2 more not listed; retrieve them via the Exa API.