Estate of Huntsman v. Commissioner
United States Tax Court
Steel and Supply each owned life insurance policies on the life of D, their president and sole shareholder. Upon D's death, the proceeds of such policies were paid to the corporations. Held: In determining the value of the stock of Steel and Supply includable in the estate of D, the proceeds of such life insurance are taken into consideration as assets of the corporations, but such proceeds are not added to the value of the stocks otherwise determined.
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Steel and Supply each owned life insurance policies on the life of D, their president and sole shareholder. Upon D's death, the proceeds of such policies were paid to the corporations. Held: In determining the value of the stock of Steel and Supply includable in the estate of D, the proceeds of such life insurance are taken into consideration as assets of the corporations, but such proceeds are not added to the value of the stocks otherwise determined. See sec. 20.2031-2(f), Estate Tax Regs. The fair market value of such stock is determined. Held, further, certain alternative positions…
1Opinion of the Court
Simpson, Judge:
In his notice of deficiency, the Commissioner determined a deficiency in the Federal estate tax of the Estate of John L. Huntsman in the amount of $97,991.40. In his second amendment to the answer, he determined such deficiency to be $107,470.13. The primary issue involves determining the fair market value of the decedent’s stock in Asheville Steel Co. and Asheville Industrial Supply Co., including determining how certain life insurance proceeds payable to such corporations by reason of the death of the decedent, are to be taken into consideration. We must also decide whether…
2Cases cited10 opinions
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Markwardt v. CommissionerUnited States Tax Court · 1975
- Palmer v. CommissionerUnited States Tax Court · 1974
- Daniel D. And Agnes H. Palmer v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1975
5 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Estate of George Blount v. Comm. of IRSCourt of Appeals for the Eleventh Circuit · 2005
- Estate of Oman v. CommissionerUnited States Tax Court · 1987
- Estate of Robert E. Cartwright, Deceased, Dorothy G. Cartwright v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999
- Koufman v. CommissionerUnited States Tax Court · 1977
- Zokoych v. SpaldingAppellate Court of Illinois · 1984
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