Legal Opinion

Estate of Glade v. Commissioner

United States Tax Court

Decided August 14, 1978No. Docket No. 8957-76Unpublished

Life insurance policies for which decedent applied were issued to his son and daughter as owners and beneficiaries. Decedent, domiciled in a community property State, provided the funds for payment of the policy premiums. The son and daughter assigned the policies as security for a loan to decedent's business.

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Life insurance policies for which decedent applied were issued to his son and daughter as owners and beneficiaries. Decedent, domiciled in a community property State, provided the funds for payment of the policy premiums. The son and daughter assigned the policies as security for a loan to decedent's business. At decedent's death, a portion of the proceeds of the daughter's policy was paid to the creditor to satisfy the balance of decedent's loan. 1. Held: decedent did not possess at his death any incidents of ownership in the policies, and so decedent's gross estate does not include half of…

1Opinion of the Court

ESTATE OF WILLIAM P. GLADE by MARY HATCHER GLADE, Co-Executrix and WILLIAM P. GLADE, JR., Co-Executor, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Glade v. Commissioner

Docket No. 8957-76.

United States Tax Court

T.C. Memo 1978-316; 1978 Tax Ct. Memo LEXIS 200; 37 T.C.M. (CCH) 1318; T.C.M. (RIA) 78316;

August 14, 1978, Filed

Life insurance policies for which decedent applied were issued to his son and daughter as owners and beneficiaries. Decedent, domiciled in a community property State, provided the funds for payment of the policy premiums. The son and daughter assigned…

2Cases cited6 opinions

  1. Commissioner v. Estate of NoelSupreme Court of the United States · 1965
  2. Schwager v. CommissionerUnited States Tax Court · 1975
  3. Beatrice Smither Parson, of the Will and Estate of George W. Parson v. United StatesCourt of Appeals for the Fifth Circuit · 1972
  4. Mrs. Frankie Lou Smith Prichard, Independent of the Estate of Houston Smith, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1968
  5. Bintliff v. United StatesCourt of Appeals for the Fifth Circuit · 1972

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