Estate of Grant H. Piggott, Deceased, David S. Piggott and Albert F. Piggott, Co-Administrators v. Commissioner of Internal Revenue

SHACKELFORD MILLER, Jr., Circuit Judge.

This case involves the liability of the estate of Grant H. Piggott, deceased, under the Federal Estate Tax with respect to the proceeds of an insurance policy on his life payable to his corporate employer, who paid the annual premiums called for by the policy and who had possession of the policy at the time of the decedent’s death. The Tax Court held the proceeds were includable in the gross estate of the decedent for Federal Estate Tax purposes.

Except for one major fact, hereinafter discussed, there is no material dispute about the facts.

J. T. Wing &…