Estate of Coleman v. Commissioner
United States Tax Court
1. Decedent's three children purchased and at all times owned a life insurance policy on her life. Decedent paid all the premiums, a portion of which were concededly in contemplation of death.
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1. Decedent's three children purchased and at all times owned a life insurance policy on her life. Decedent paid all the premiums, a portion of which were concededly in contemplation of death. Held, no portion of the proceeds of the insurance is includable in her estate under sec. 2035, I.R.C. 1954, the amount includable being limited to the premiums paid in contemplation of death. 2. Decedent, as lessor of a lease, expiring in 2057, received a security deposit which was returnable only upon the expiration of the lease and then only if the lessee had performed all of the numerous obligations…
1Opinion of the Court
Estate of Inez G. Coleman, Deceased, D. C. Coleman, Jr., Executor, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Coleman v. Commissioner
Docket No. 4333-68
United States Tax Court
52 T.C. 921; 1969 U.S. Tax Ct. LEXIS 62;
September 9, 1969, Filed
Decision will be entered under Rule 50.
1. Decedent's three children purchased and at all times owned a life insurance policy on her life. Decedent paid all the premiums, a portion of which were concededly in contemplation of death. Held, no portion of the proceeds of the insurance is includable in her estate under sec. 2035, I.R.C.…
Also in this document: Dissent · Tietjens; Dissent · Raum; Dissent · Dawson.
2Cases cited24 opinions
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- Milliken v. United StatesSupreme Court of the United States · 1931
- Commissioner of Internal Revenue v. MaresiCourt of Appeals for the Second Circuit · 1946
- United States v. Manufacturers National Bank of DetroitSupreme Court of the United States · 1960
- Estate of Mary Redding Shedd, First National Bank of Arizona, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1963
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