Estate of Wien v. Commissioner
United States Tax Court
Held, the absolute and unrestricted owner of life insurance policies on the life of another possesses, at the instant of his simultaneous death with the insured, property rights which are includable in his "gross estate" at a value equal to the entire proceeds payable under the terms of the policies. Estate of Roger M. Chown, 51 T.C. 140 (1968), followed.
1Opinion of the Court
OPINION
Dawson, Judge:
In these consolidated cases respondent determined the following deficiencies in Federal estate taxes:
Petitioner Pocket No. Deficiency
Estate of Ellen M. Wien_ 5364-66 $55, 089. 01
Estate of Sidney A. Wien____ 5365-66 74, 093. 25
Petitioners claim overpayments in their estate taxes as follows:
Petitioner Amount
Estate of Ellen M. Wien_$32,800
Estate of Sidney A. Wien_ 7, 600
The only issue remaining in these cases involves a determination of the value, if any, includable in the gross estates of a husband and wife who died simultaneously, each holding the ownership rights in life…
2Cases cited2 opinions
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Estate of Chown v. CommissionerUnited States Tax Court · 1968
3Cited by16 opinions
- Estate of Gloria A. Lion, Deceased, Morton E. Rome and George L. Clarke, Executors v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1971
- Estate of Ellen M. Wien, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
- Estate of Harriet H. Chown, Deceased, Howard B. Somer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Estate of Lion v. CommissionerUnited States Tax Court · 1969
- Old Kent Bank & Trust Co. v. United StatesCourt of Appeals for the Sixth Circuit · 1970
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