Commissioner of Internal Revenue v. Ames

BRIGGLE, District Judge.

This is a petition to review a decision of the Board of Tax Appeals reversing an order of the Commissioner, who had found a deficiency in estate tax against the estate of Knowlton L. Ames, deceased.

Decedent left an estate valued at $2,-025,976.24; $847,766.27 of which were tangible assets, and $1,178,209.97 'of which were the proceeds of life insurance contracts payable to a trustee and to an individual. Valid claims against the estate totaled $6,721,007.21, none of which constituted a charge against the proceeds of the life insurance policies. Such proceeds, however,…