Noel v. Commissioner
United States Tax Court
1. Proceeds of so-called flight or accident insurance paid to beneficiary upon death of airline passenger held includable in decedent's gross estate as "insurance under policies on the life of the decedent."
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1. Proceeds of so-called flight or accident insurance paid to beneficiary upon death of airline passenger held includable in decedent's gross estate as "insurance under policies on the life of the decedent." Sec. 2042(2), I.R.C. 1954. Leopold Ackerman, 15 B.T.A. 635, followed. 2. Decedent's right to change beneficiary in such policies held not destroyed by delivery of the policies to beneficiary in the circumstances of this case; decedent had requisite incident of ownership within section 2042(2).
1Opinion of the Court
Estate of Marshal L. Noel, Deceased, William H. Frantz and Ruth M. Noel, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent
Noel v. Commissioner
Docket No. 90028
United States Tax Court
39 T.C. 466; 1962 U.S. Tax Ct. LEXIS 18;
November 28, 1962, Filed
Decision will be entered under Rule 50.
1. Proceeds of so-called flight or accident insurance paid to beneficiary upon death of airline passenger held includable in decedent's gross estate as "insurance under policies on the life of the decedent." Sec. 2042(2), I.R.C. 1954. Leopold Ackerman, 15 B.T.A. 635, followed.
2. Decedent's…
2Cases cited21 opinions
- United States v. Security Trust & Savings BankSupreme Court of the United States · 1950
- Helvering v. City Bank Farmers Trust Co.Supreme Court of the United States · 1935
- Hurd v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1947
- Hurd v. CommissionerUnited States Tax Court · 1946
- Katzman v. Ætna Life InsuranceNew York Court of Appeals · 1955
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