Legal Opinion

Estate of Bloch v. Commissioner

United States Tax Court

Decided May 25, 1982No. Docket No. 2667-78Published

Decedent was the trustee of a trust established by his father in 1946 for the benefit of decedent's children. The trust agreement vested the trustee with the same rights and powers over insurance policies held by the trust "as he would have as the absolute owner thereof." As trustee, decedent caused the trust to purchase three insurance policies on his life.

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Decedent was the trustee of a trust established by his father in 1946 for the benefit of decedent's children. The trust agreement vested the trustee with the same rights and powers over insurance policies held by the trust "as he would have as the absolute owner thereof." As trustee, decedent caused the trust to purchase three insurance policies on his life. Subsequently, decedent as trustee executed assignments of those insurance policies as collateral security for personal obligations and obligations of a corporation in which decedent was an officer, director, and 50-percent shareholder.…

1Opinion of the Court

Estate of Harry Bloch, Jr., Deceased, First Wisconsin Trust Company, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Bloch v. Commissioner

Docket No. 2667-78

United States Tax Court

78 T.C. 850; 1982 U.S. Tax Ct. LEXIS 94; 78 T.C. No. 59;

May 25, 1982, Filed

Decision will be entered under Rule 155.

Decedent was the trustee of a trust established by his father in 1946 for the benefit of decedent's children. The trust agreement vested the trustee with the same rights and powers over insurance policies held by the trust "as he would have as the absolute…

2Cases cited20 opinions

  1. Crooks v. HarrelsonSupreme Court of the United States · 1930
  2. United States v. O'MALLEYSupreme Court of the United States · 1966
  3. Lober v. United StatesSupreme Court of the United States · 1953
  4. Estate of James H. Lumpkin, Jr., Deceased. Christine T. Hamilton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
  5. Estate of Lumpkin v. CommissionerUnited States Tax Court · 1971

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