Collino v. Commissioner
United States Tax Court
1. The decedent's mother paid all of the premiums on 8 policies of insurance on decedent's life. She was the beneficiary and received the proceeds upon decedent's death. The evidence establishes that the decedent possessed an incident of ownership in the policies. Petitioner has failed to establish that decedent did not possess other incidents of ownership.
Read the full summary
1. The decedent's mother paid all of the premiums on 8 policies of insurance on decedent's life. She was the beneficiary and received the proceeds upon decedent's death. The evidence establishes that the decedent possessed an incident of ownership in the policies. Petitioner has failed to establish that decedent did not possess other incidents of ownership. Held, the proceeds of the insurance, $ 61,266.72, are includible in decedent's gross estate under the provisions of section 811 (g) (2) (B) of the 1939 Code. 2. Upon the facts, held that failure to file the estate tax return within the…
1Opinion of the Court
Estate of Michael Collino, Deceased, Mortimer J. Goodstein, Administrator d. b. n., Petitioner, v. Commissioner of Internal Revenue, Respondent
Collino v. Commissioner
Docket No. 46913
United States Tax Court
25 T.C. 1026; 1956 U.S. Tax Ct. LEXIS 269;
February 10, 1956, Filed
Decision will be entered under Rule 50.
1. The decedent's mother paid all of the premiums on 8 policies of insurance on decedent's life. She was the beneficiary and received the proceeds upon decedent's death. The evidence establishes that the decedent possessed an incident of ownership in the policies. Petitioner has failed to…
2Cases cited9 opinions
- Burnet v. HoustonSupreme Court of the United States · 1931
- Haywood Lumber & Mining Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1950
- Fairfax Mut. Wood Products Co. v. CommissionerUnited States Tax Court · 1945
- Patino v. CommissionerUnited States Tax Court · 1949
- Commissioner of Internal Revenue v. PatinoCourt of Appeals for the Fourth Circuit · 1950
4 more not listed; retrieve them via the Exa API.