Cronin v. Commissioner
United States Tax Court
1. Decedent, who died in 1940, irrevocably assigned and transferred to his wife in 1935 insurance policies taken out by him on his own life.
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1. Decedent, who died in 1940, irrevocably assigned and transferred to his wife in 1935 insurance policies taken out by him on his own life. Held, under the facts, that the policies were transferred in contemplation of death within the meaning of section 811 (c) of the Internal Revenue Code and are includible in decedent's estate. 2. The value of a certain apartment building determined. 3. Held, ignorance of the law does not constitute reasonable cause for failure to file estate tax return within the time prescribed by law and the penalty provisions of section 3612 (d), Internal Revenue Code,…
1Opinion of the Court
OPINION.
Hill, Judge:
Insurance policies. — Kespondent contends that the transferred insurance policies are includible in decedent’s estate as transfers made in contemplation of or intended to take effect in possession or enjoyment at or after decedent’s death within the meaning of section 811 (c) of the Internal Revenue Code.1 Petitioner contends that the policies'were not transferred in contemplation of death, but were transferred for reasons associated with life, and that the transfers were not to take effect at or after death, but were absolute transfers when made. We agree with respondent…
2Cases cited1 opinion
- United States v. WellsSupreme Court of the United States · 1931
3Cited by26 opinions
- Hurd v. CommissionerUnited States Tax Court · 1947
- Ruthrauff v. CommissionerUnited States Tax Court · 1947
- Estate of Garrett v. CommissionerUnited States Tax Court · 1947
- Flick's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
- Estate of Hunt v. CommissionerUnited States Tax Court · 1950
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