Boston Safe Deposit & T. Co. v. Commissioner of Int. Rev.

BINGHAM, Circuit Judge.

This is a petition to review an order or decision of the Board of Tax Appeals of January 14, 1938, determining a deficiency estate tax in the amount of $1,706.07, of which $1,554 is in dispute. The petitioner, a Massachusetts corporation) is the.executor of the estate of Willard T. Carleton, late of Winchester, Mass., who died July 12, 1933. The facts in the case are not in dispute.

Carleton purchased insurance on his life in the amount of $124,054, payable to the “Boston Safe Deposit & Trust Company, trustee,” without specifying in the policies the beneficiaries of the…