Estate of Bluestein v. Commissioner

OPINION.

Van Fossan, Judge:

The first issue is whether the respondent erred by including in the gross estate all of the assets standing in the decedent’s name at his death.

It is appropriate that we summarize the essential facts in order to emphasize the nature of the problem.

The decedent, A. Bluestein, after several unsuccessful business ventures, moved to Corpus Christi, Texas, in 1914 and entered into a partnership to operate a small clothing store. Within a few years the decedent became the sole proprietor. He began this venture with an original capital of $1,000 borrowed on a life insurance…