In re Estate of White

The sole issue before the court is whether the Tax Commissioner properly increased the value of stock in two closely held corporations, for estate tax purposes, by listing as an asset of the corpora*357tions the life insurance proceeds that were receivable by the corporations upon the death of the stockholder. The executors of the estate of James F. White, Sr., who was the major stockholder in the two closely held corporations, contend that R.C. 5731.12(A) precludes the commissioner from listing proceeds derived from White’s life insurance policies as assets of the corporations because this…