Legal Opinion
In Re Estate of Marshal L. Noel, Deceased. William H. Frantz and Ruth M. Noel, Executors v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided June 17, 1964No. 14441_1PublishedCited by 10 opinions
1Opinion of the Court
WILLIAM F. SMITH, Circuit Judge.
This case is here on a petition to review a decision of the Tax Court. The principal question for decision is whether the proceeds of an air flight insurance policy paid to the designated beneficiary are includible in the gross estate of the •decedent under § 2042(2) of the 1954 Internal Revenue Code, 26 U.S.C.A. § 2042(2). The question is admittedly one of novel impression not wholly free of difficulty.
The pertinent provisions of the cited statute read as follows:
“The value of the gross estate shall include the value of all property—
“(2) * * * To the extent of…
2Cases cited17 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Church of the Holy Trinity v. United StatesSupreme Court of the United States · 1892
- Crane v. CommissionerSupreme Court of the United States · 1947
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
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3Cited by10 opinions
- Commissioner v. Estate of NoelSupreme Court of the United States · 1965
- Fuchs v. CommissionerUnited States Tax Court · 1966
- Fruehauf v. CommissionerUnited States Tax Court · 1968
- Gorman v. United StatesDistrict Court, E.D. Michigan · 1968
- Simmons v. Continental Casualty CompanyDistrict Court, D. Nebraska · 1968
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