Brous v. Commissioner
United States Tax Court
Life insurance which to the extent of decedent's payments of the premiums prior to 1941 is includible in gross estate only in the event of the retention by decedent of an "incident of ownership" (Revenue Act of 1942, section 404, amending Internal Revenue Code, section 811 (g), held properly includible in view of decedent's reversionary interest in the insurance policies. Sec. 404 (c).
1Opinion of the Court
OPINION.
Oppeb, Judge:
By this proceeding petitioner seeks a redetermination of a deficiency in estate tax in the amount of $8,037.98. The decedent died on January 3, 1943. The estate tax return was filed with the collector of internal revenue for the fourteenth collection district of New York.
The primary question is the propriety of the inclusion of the proceeds of three insurance policies in decedent’s estate.
The case was submitted upon a stipulation of facts, and the facts so stipulated are hereby found accordingly. Only those facts which we regard as pertinent to our disposition of the case…
2Cases cited2 opinions
- Welliver v. CommissionerUnited States Tax Court · 1947
- Early v. RogersSupreme Court of the United States · 1854
3Cited by5 opinions
- Saxton v. CommissionerUnited States Tax Court · 1949
- Bowers v. CommissionerUnited States Tax Court · 1955
- Brous v. CommissionerUnited States Tax Court · 1948
- Estate of J. Rollin French v. CommissionerUnited States Tax Court · 1948
- Saxton v. CommissionerUnited States Tax Court · 1949