- 2 -
corporation. CSB bought life insurance which paid $5,062,029 to
CSB upon decedent’s death. CSB paid that amount to decedent’s
estate. After concessions, the issues for decision are:
1. Whether the life insurance proceeds were paid to
decedent's estate solely to redeem his CSB stock, as petitioner
contends, or partly for his CSB stock and partly for any claims
for cases or work in process, as respondent contends. We hold
that $1,105,762 of the payment was for decedent's CSB stock, and
the remainder was for any claims for cases or work in process.
2. Whether the part of the payment which was made for any
claims for cases or work in process is income in respect of a
decedent under section 691. We hold that it is.
Section references are to the Internal Revenue Code in
effect for the year in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
At the request of CSB, which request neither party opposed,
we sealed parts of the transcript and certain documents which
were admitted into evidence.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Dorothy G. Cartwright lived in California when she filed the
petition.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011