Legal Opinion

Estate of Chown v. Commissioner

United States Tax Court

Decided October 23, 1968No. Docket Nos. 3232-67, 3233-67PublishedCited by 14 opinions

The decedent was the absolute and unrestricted owner of a life insurance policy at the time of her death. Decedent and the insured (her husband) died simultaneously. Held, the amount representing the policy which is properly includable in the decedent's gross estate under sec. 2033, I.R.C. 1954, is an amount equal to the proceeds that were payable under the terms of the policy.

1Opinion of the Court

OPINION

Tietjens, Judge:

The Commissioner determined deficiencies in estate tax for the taxable year 1964 in the amounts of $29,488.14 and $27,045.81, respectively, for the separate estates of Roger M. Chown and Harriet H. Chown, deceased.

The deficiencies were determined by including in the gross estates of both decedents $102,389.40, representing the proceeds of a life insurance policy owned by Harriet H. Chown and insuring Roger M. Chown. The Commissioner has bound himself by his stipulation that the deficiencies of the two estates have been determined in the alternative.

All of the facts have…

2Cases cited5 opinions

  1. Chase National Bank v. United StatesSupreme Court of the United States · 1929
  2. Commissioner v. Estate of NoelSupreme Court of the United States · 1965
  3. American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
  4. Goodman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1946
  5. Pritchard v. CommissionerUnited States Tax Court · 1944

3Cited by14 opinions

  1. Estate of Gloria A. Lion, Deceased, Morton E. Rome and George L. Clarke, Executors v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1971
  2. Estate of Ellen M. Wien, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1971
  3. Estate of Wien v. CommissionerUnited States Tax Court · 1968
  4. Estate of Harriet H. Chown, Deceased, Howard B. Somer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
  5. Estate of Lion v. CommissionerUnited States Tax Court · 1969

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