Selling v. Commissioner
United States Tax Court
1. Cash gifts from husband to wife held not made in contemplation of death. 2. Premiums on an insurance policy on decedent's life were not paid directly or indirectly by him so as to require inclusion of the insurance proceeds in his gross estate. 3. Bequest to wife of insurance renewal commissions payable over periods up to 9 years was a terminable interest precluding allowance of the marital deduction where decedent's will further provided that any commissions unpaid at…
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1. Cash gifts from husband to wife held not made in contemplation of death. 2. Premiums on an insurance policy on decedent's life were not paid directly or indirectly by him so as to require inclusion of the insurance proceeds in his gross estate. 3. Bequest to wife of insurance renewal commissions payable over periods up to 9 years was a terminable interest precluding allowance of the marital deduction where decedent's will further provided that any commissions unpaid at wife's death should pass to son notwithstanding wife's right to dispose of rights to commissions at any time.
1Opinion of the Court
Estate of Julius Selling, Deceased, Fred M. Selling and Hanna Selling, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent
Selling v. Commissioner
Docket No. 46830
United States Tax Court
24 T.C. 191; 1955 U.S. Tax Ct. LEXIS 188;
May 13, 1955, Filed
Decision will be entered under Rule 50.
1. Cash gifts from husband to wife held not made in contemplation of death.
2. Premiums on an insurance policy on decedent's life were not paid directly or indirectly by him so as to require inclusion of the insurance proceeds in his gross estate.
3. Bequest to wife of insurance renewal…
2Cases cited18 opinions
- United States v. WellsSupreme Court of the United States · 1931
- Leggett v. . FirthNew York Court of Appeals · 1892
- Pipe v. CommissionerUnited States Tax Court · 1954
- Estate of Johnson v. CommissionerUnited States Tax Court · 1948
- In Re the Accounting of Ithaca Trust Co.New York Court of Appeals · 1917
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