Estate of Montgomery v. Comm'r
United States Tax Court
Decedent purchased an annuity for $ 2,200,000 and established irrevocable trusts for his beneficiaries. By purchase of the annuity, decedent became entitled, without physical examination, to purchase or to permit the purchase by the trusts of an aggregate amount of insurance on his life of $ 2 million.
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Decedent purchased an annuity for $ 2,200,000 and established irrevocable trusts for his beneficiaries. By purchase of the annuity, decedent became entitled, without physical examination, to purchase or to permit the purchase by the trusts of an aggregate amount of insurance on his life of $ 2 million. He permitted the purchase thereof by the two trusts making a simultaneous gift of cash to each in the amount of the premiums on such life insurance and paying gift tax thereon. The proceeds of the insurance were received by the trusts upon the death of decedent but were not included in his…
1Opinion of the Court
Estate of Lafayette Montgomery, Deceased, Trust Company of Georgia, Arthur L. Montgomery, and George A. Montgomery, Executors, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Montgomery v. Comm'r
Docket No. 754-69
United States Tax Court
56 T.C. 489; 1971 U.S. Tax Ct. LEXIS 125;
June 14, 1971, Filed
Decision will be entered under Rule 50.
Decedent purchased an annuity for $ 2,200,000 and established irrevocable trusts for his beneficiaries. By purchase of the annuity, decedent became entitled, without physical examination, to purchase or to permit the purchase by the trusts of…
2Cases cited12 opinions
- Helvering v. Le GierseSupreme Court of the United States · 1941
- Ritter v. Mutual Life Ins. Co. of NYSupreme Court of the United States · 1898
- Estate of Keller v. CommissionerSupreme Court of the United States · 1941
- Fidelity-Philadelphia Trust Co. v. SmithSupreme Court of the United States · 1958
- Helvering v. TylerCourt of Appeals for the Eighth Circuit · 1940
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