Legal Opinion

Estate of Carlstrom v. Commissioner

United States Tax Court

Decided January 28, 1981No. Docket No. 1143-79Published

Wife of decedent applied for an "employer pay all" split-dollar life insurance policy on decedent's life, specifying herself as owner and beneficiary. After the insurance policy became effective, the insurance company sent a policy amendment to the decedent's employer, CFI, making CFI the owner of said policy. At age 49, and within 3 years of the effective date of said policy, decedent died. At the time of his death, the decedent was the owner of 71 percent of the CFI stock.

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Wife of decedent applied for an "employer pay all" split-dollar life insurance policy on decedent's life, specifying herself as owner and beneficiary. After the insurance policy became effective, the insurance company sent a policy amendment to the decedent's employer, CFI, making CFI the owner of said policy. At age 49, and within 3 years of the effective date of said policy, decedent died. At the time of his death, the decedent was the owner of 71 percent of the CFI stock. Held, under Missouri law the policy amendment was ineffective to transfer ownership of the policy to CFI. Held,…

1Opinion of the Court

Estate of Howard F. Carlstrom, Deceased, Betty J. Carlstrom, Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Carlstrom v. Commissioner

Docket No. 1143-79

United States Tax Court

76 T.C. 142; 1981 U.S. Tax Ct. LEXIS 183;

January 28, 1981, Filed

Decision will be entered under Rule 155.

Wife of decedent applied for an "employer pay all" split-dollar life insurance policy on decedent's life, specifying herself as owner and beneficiary. After the insurance policy became effective, the insurance company sent a policy amendment to the decedent's employer, CFI, making CFI the…

2Cases cited20 opinions

  1. United States v. WellsSupreme Court of the United States · 1931
  2. Chase National Bank v. United StatesSupreme Court of the United States · 1929
  3. Allen v. Trust Co. of Ga.Supreme Court of the United States · 1946
  4. Estate of Ford v. CommissionerUnited States Tax Court · 1969
  5. Coffman Industries, Inc. v. Gorman-Taber Co.Missouri Court of Appeals · 1975

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