Legal Opinion

Estate of Perl v. Commissioner

United States Tax Court

Decided May 27, 1981No. Docket No. 3055-79Published

The decedent's employer purchased a life insurance and disability benefits contract for the decedent. The decedent died while in active service, and the insurance proceeds were paid to his designated beneficiaries. Held, the value of the insurance proceeds is includable in the decedent's gross estate pursuant to sec. 2042(2), I.R.C. 1954, because the decedent possessed an incident of ownership.

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The decedent's employer purchased a life insurance and disability benefits contract for the decedent. The decedent died while in active service, and the insurance proceeds were paid to his designated beneficiaries. Held, the value of the insurance proceeds is includable in the decedent's gross estate pursuant to sec. 2042(2), I.R.C. 1954, because the decedent possessed an incident of ownership. Held, further, the value of the insurance proceeds is not excluded from the decedent's gross estate pursuant to sec. 2039(c), I.R.C. 1954, because they were not part of a pension plan nor payable under…

1Opinion of the Court

Estate of William Perl, Deceased, Sidney Finkel and Helen W. Finkel, Executors, Petitioner v. Commissioner of Internal Revenue, Respondent

Estate of Perl v. Commissioner

Docket No. 3055-79

United States Tax Court

76 T.C. 861; 1981 U.S. Tax Ct. LEXIS 122; 2 Employee Benefits Cas. (BNA) 1450;

May 27, 1981, Filed

Decision will be entered for the respondent.

The decedent's employer purchased a life insurance and disability benefits contract for the decedent. The decedent died while in active service, and the insurance proceeds were paid to his designated beneficiaries. Held, the value of the insurance…

2Cases cited10 opinions

  1. Helvering v. Le GierseSupreme Court of the United States · 1941
  2. Commissioner v. Estate of NoelSupreme Court of the United States · 1965
  3. Fusz v. CommissionerUnited States Tax Court · 1966
  4. Estate of J. William Bahen, Deceased, Kathleen Privett Bahen, Sole v. The United StatesUnited States Court of Claims · 1962
  5. Mascot Oil Co. v. United StatesSupreme Court of the United States · 1931

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