Estate of Alto B. Cervin, Deceased, Bennett W. Cervin, & Nita-Carol Cervin Miskovitch v. Commissioner of Internal Revenue

DUHÉ, Circuit Judge:

The Estate of Alto B. Cervin petitioned the United States Tax Court for a redetermination of a federal estate tax deficiency asserted against it by the Internal Revenue Service. The alleged deficiency was based upon a determination by the Commissioner that (1) the decedent’s gross estate should include one hundred percent of the proceeds of three whole life insurance policies, and (2) the estate was not entitled to a twenty-five percent discount with respect to the valuation of eer- tain real property. The Tax Court held that (1) the gross estate includes one hundred…