Estate of Bartlett v. Commissioner
United States Tax Court
B, who was the owner of certain life insurance policies and had an interest in a group term life insurance policy (which by its terms was unassignable), executed an irrevocable assignment of all his right, title, and interest in the policies to the NTC bank, as trustee, pursuant to an insurance trust agreement. He signed change of beneficiary forms, naming the bank as beneficiary of each policy.
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B, who was the owner of certain life insurance policies and had an interest in a group term life insurance policy (which by its terms was unassignable), executed an irrevocable assignment of all his right, title, and interest in the policies to the NTC bank, as trustee, pursuant to an insurance trust agreement. He signed change of beneficiary forms, naming the bank as beneficiary of each policy. The insurance companies accepted the beneficiary designations and upon B's death paid the proceeds to the trustee bank. Held, (1) that the proceeds of all the life insurance policies, except the group…
1Opinion of the Court
OPINION
Dawson, Judge:
Respondent determined a deficiency of $5,518.99 in the estate tax of petitioner. This asserted deficiency and a claimed overpayment of $3,512.72 are in dispute. In addition, petitioner has reserved the right to claim a deduction for reasonable legal fees incurred in this proceeding.
Concessions have been made by both parties. The issue presented for our decision is whether the decedent possessed at his death any incidents of ownership' in certain life insurance policies and a group term life insurance policy so as to require the inclusion of the proceeds of such insurance…
2Cases cited14 opinions
- Commissioner v. Estate of NoelSupreme Court of the United States · 1965
- Mutual Ben. Life Ins. v. SwettCourt of Appeals for the Sixth Circuit · 1915
- United States v. Rhode Island Hospital Trust CompanyCourt of Appeals for the First Circuit · 1966
- Gurnett v. Mutual Life InsuranceIllinois Supreme Court · 1934
- Landorf v. United StatesUnited States Court of Claims · 1969
9 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Estate of O'Daniel v. United StatesCourt of Appeals for the Fifth Circuit · 1993
- Estate of Jordahl v. CommissionerUnited States Tax Court · 1975
- Cole v. CommissionerUnited States Tax Court · 1971
- Estate of Bartlett v. CommissionerUnited States Tax Court · 1970
- Estate of Jordahl v. CommissionerUnited States Tax Court · 1975
3 more not listed; retrieve them via the Exa API.