Estate of Levy v. Commissioner
United States Tax Court
Petitioner owned 80.4 percent of the issued and outstanding voting stock of Levy Bros. and all of its issued and outstanding nonvoting stock. The corporation owned life insurance policies on decedent's life, payable to decedent's widow. Held, sec. 20.2042-1(c)(6), Estate Tax Regs., is valid in requiring inclusion of insurance proceeds in a decedent's gross estate if the decedent is a controlling shareholder but not the sole shareholder.
1Opinion of the Court
Estate of Milton L. Levy, Deceased, John Levy, Co-Executor, Jeffrey R. Levy, Co-Executor, Iris Levy, Co-Executrix, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Levy v. Commissioner
Docket No. 2354-75
United States Tax Court
70 T.C. 873; 1978 U.S. Tax Ct. LEXIS 63;
September 7, 1978, Filed
Decision will be entered for the respondent.
Petitioner owned 80.4 percent of the issued and outstanding voting stock of Levy Bros. and all of its issued and outstanding nonvoting stock. The corporation owned life insurance policies on decedent's life, payable to decedent's widow. Held, sec.…
2Cases cited14 opinions
- United States v. Rhode Island Hospital Trust CompanyCourt of Appeals for the First Circuit · 1966
- Estate of James H. Lumpkin, Jr., Deceased. Christine T. Hamilton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- H. F. Campbell Co. v. CommissionerUnited States Tax Court · 1969
- H. F. Campbell Company (Formerly H. F. Campbell Construction Company) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1971
- Estate of Gilman v. CommissionerUnited States Tax Court · 1975
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