In re the Estate of Davis

William J. Regan, S.

Petitioner appeals from the pro forma tax order entered December 28,1964 which fixed and determined the estate tax in the sum of $93.97.

Petitioner contends that the State Tax Commission failed to include in the gross estate the proceeds of a certain life insurance policy and that said proceeds were not properly credited against the New York estate tax.

The State Tax Commission argues that this is not the type of insurance that qualifies for the exemption under the appropriate tax regulations. The policy in question was issued in June of 1963 and apparently represented…