Industrial Trust Co. v. United States

LITTLETON, Judge.

The question for decision is whether the proceeds of a life insurance policy may be included in the gross estate of the insured for the purpose of the estate tax imposed by the Revenue Act of 1926 when the policy provides for payment to certain named beneficiaries, but, in the event of their death prior to that of the insured, then to the executor, administrators, or assigns of the insured, and when the policy is silent as to whether the insured might change the beneficiary, withdraw the cash surrender value, or pledge the policy as security for a loan.

The insurance policy in…