Legal Opinion

Tuohy v. Commissioner

United States Tax Court

Decided February 17, 1950No. Docket No. 16327Published

Upon the facts, held, decedent and not his mother during her lifetime elected to take the proceeds of two life insurance policies under an optional provision of the policies; held, further, that such election constituted a transfer of property within the meaning of section 811 (c) of the Internal Revenue Code. Estate of Mabel E. Morton, 12 T. C. 380.

1Opinion of the Court

Estate of John Joseph Tuohy, Junior, Deceased, Bank of America National Trust and Savings Association, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent

Tuohy v. Commissioner

Docket No. 16327

United States Tax Court

14 T.C. 245; 1950 U.S. Tax Ct. LEXIS 273;

February 17, 1950, Promulgated

Decision will be entered under Rule 50.

Upon the facts, held, decedent and not his mother during her lifetime elected to take the proceeds of two life insurance policies under an optional provision of the policies; held, further, that such election constituted a transfer of property within the…

2Cases cited6 opinions

  1. Chase National Bank v. United StatesSupreme Court of the United States · 1929
  2. Higgs v. CommissionerUnited States Tax Court · 1949
  3. Johnston v. KearnsCalifornia Court of Appeal · 1930
  4. Morton v. CommissionerUnited States Tax Court · 1949
  5. Estate of BurnettCalifornia Court of Appeal · 1941

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