Estate of Madsen v. Commissioner of Internal Revenue

This is a federal estate tax case wherein appellee, Commissioner of Internal Revenue, sought to recover $24,412.84 in estate taxes from appellant, Estate of Mattias Arnold Madsen. A deficiency was noted for failure to include one-half of the proceeds of a $200,000 life insurance policy in the gross estate of Mr. Madsen. The United States Tax Court ruled that one-half of the insurance proceeds were includable in the estate under the Internal Revenue Code of 1954, 26 U.S.C. § 2042(2). An appeal was taken to the United States Court of Appeals for the Ninth Circuit. A majority of the hearing…