Estate of Fruehauf v. Commissioner

PECK, Circuit Judge.

Harry R. Fruehauf (hereinafter “the decedent”) died on April 29, 1962, in Detroit, Michigan. An estate tax return filed with the district director of internal revenue for Detroit, Michigan, was subsequently determined by the Commissioner of Internal Revenue (hereinafter “the Commissioner”) to disclose a deficiency in the tax upon the estate. The basis of the Commissioner’s deficiency determination was the failure by the executors to include in decedent’s gross estate the value of the proceeds of six insurance policies on decedent’s life in which the Commissioner determined…