Grover H. Hope, of the Estate of Beverly J. Hope, Deceased v. United States of America, Internal Revenue Service

WISDOM, Circuit Judge:

In this estate tax dispute, we are asked to decide whether the proceeds of three term life insurance policies should be included in the estate as gifts in contemplation of death under section 2035 of the Internal Revenue Code of 1954 [26 U.S.C. § 2035], The District Court for the Northern District of Texas tried the case without a jury on stipulated facts, and held that the decedent transferred the insurance policies but that the transfer was not made in contemplation of death. 1 The estate was granted a refund, and the government appeals. On cross appeal, the estate…