Estate of Beauregard v. Commissioner
United States Tax Court
At the time of his accidental death, the decedent was a covered person under his employer's travel accident policy. By its terms, the policy vested in the decedent certain incidents of ownership, including the right to designate and change beneficiaries and elect installment payments of the proceeds.
Read the full summary
At the time of his accidental death, the decedent was a covered person under his employer's travel accident policy. By its terms, the policy vested in the decedent certain incidents of ownership, including the right to designate and change beneficiaries and elect installment payments of the proceeds. However, during his lifetime decedent and his ex-wife had entered into a property settlement agreement, the terms of which were incorporated into a divorce decree (court order) whereby decedent was required to "maintain the minor children as beneficiaries in connection with any group accident and…
1Opinion of the Court
OPINION
Nims, Judge:
Respondent has determined an estate tax deficiency of $25,182.62. Because of a concession made by petitioners, the sole remaining issue for our determination is whether the proceeds of a travel accident policy under which the decedent was a “covered person” are includable in his gross estate.
The facts in this case were fully stipulated. The stipulation of facts and attached exhibits are incorporated herein by reference.
Theodore E. Beauregard III and Yvonne Marie Beauregard, who, as the fiduciaries of the decedent’s estate, are the petitioners herein, resided in Woodland…
2Cases cited22 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Commissioner v. Estate of NoelSupreme Court of the United States · 1965
- M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
- Commissioner of Internal Revenue v. TreganowanCourt of Appeals for the Second Circuit · 1950
17 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Estate of Smead v. CommissionerUnited States Tax Court · 1982
- Estate of Beauregard v. CommissionerUnited States Tax Court · 1980
- Estate of Kahanic v. Comm'rUnited States Tax Court · 2012
- Estate of Smead v. CommissionerUnited States Tax Court · 1982