Estate of Edmonds v. Commissioner

OPINION.

Black, Judge:

As has already been stated in our preliminary statement the Commissioner has determined the deficiency in estate tax here involved by adding to the gross estate reported on the return, $20,000 which was paid to the widow and five children of decedent upon his death by the New York Stock Exchange. The Commissioner has done this on the ground that the $20,000 in question was insurance within the meaning of section 811 (g) (2) of the Internal Revenue Code.1

Petitioner contests the correctness of respondent’s determination upon the following grounds:

1. The amount received by…