Estate of Mudge v. Commissioner

OPINION.

Offer, Judge:

Respondent has determined that insurance policies placed in a trust by decedent 14 years before his death were transferred in contemplation of death. As in the Estate of Louis Richards, 20 T. C. 904, affirmed per curiam (C. A. 9) 221 F. 2d 808, the only direct evidence of decedent’s motive for assigning the policies was a desire to protect them from the dangers of his speculative business. He had previously used them as a source of borrowed funds and one of his lawyers testified that “[h]e had had a bad experience to borrow on his life insurance and was not going to get…