Fruehauf v. Commissioner
United States Tax Court
Decedent's wife owned several insurance policies taken out on the life of her husband. She died 14 months before her husband. In the wife's will it was provided that the policies were to go to a trust of which decedent was cotrustee and income beneficiary.
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Decedent's wife owned several insurance policies taken out on the life of her husband. She died 14 months before her husband. In the wife's will it was provided that the policies were to go to a trust of which decedent was cotrustee and income beneficiary. The trustees were given broad powers to retain policies as long as they desired, to assign some of the policies to obtain money to pay premiums, to designate themselves as beneficiaries, and to sell or convert policies for cash surrender value. Held, the proceeds of the policies were correctly included in decedent's estate and he held…
1Opinion of the Court
OPINION
Mulroney, Judge:
Respondent determined a deficiency in the estate tax in the Estate of Harry R. Fruehauf, in the amount of $75,462.68.
Many issues have been resolved by stipulations and concessions. There is but one issue that is now for decision, namely, whether there should be included in decedent’s gross estate the value of the proceeds of several insurance policies written on his life.
All of the facts have been stipulated and they are found accordingly.
The National Bank of Detroit, Harry R. Fruehauf, Jr., and Thomas L. Munson, are the duly appointed, qualified, and acting executors…
2Cases cited23 opinions
- Reinecke v. SmithSupreme Court of the United States · 1933
- Commissioner v. Estate of HolmesSupreme Court of the United States · 1946
- Commissioner v. Estate of NoelSupreme Court of the United States · 1965
- United States v. Rhode Island Hospital Trust CompanyCourt of Appeals for the First Circuit · 1966
- Nettleton v. CommissionerUnited States Tax Court · 1945
18 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Estate of Craft v. CommissionerUnited States Tax Court · 1977
- Estate of John J. Connelly, Sr. (Deceased) and Ellen C. King v. United StatesCourt of Appeals for the Third Circuit · 1977
- Estate of Fruehauf v. CommissionerCourt of Appeals for the Sixth Circuit · 1970
- Estate of Skifter v. CommissionerUnited States Tax Court · 1971
- Estate of Bloch v. CommissionerUnited States Tax Court · 1982
14 more not listed; retrieve them via the Exa API.