Estate of William G. Street, Deceased, Anne Street Skipper, Executrix - Page 1

                                 T.C. Memo. 1997-32                                   

                               UNITED STATES TAX COURT                                

                       ESTATE OF WILLIAM G. STREET, DECEASED,                         
                    ANNE STREET SKIPPER, EXECUTRIX, Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 376-95.                   Filed January 21, 1997.           

                    D, a married resident of Texas, bought certain                    
               life insurance policies that were community property.                  
               He designated his estate as beneficiary of these                       
               policies, compensating his wife for her one-half                       
               interest in the policies, and all the insurance was so                 
               paid at his death.  Held, one-half the value of the                    
               policies may not be excluded from D's gross estate for                 
               Federal estate tax purposes.                                           

               Emily A. Parker, for petitioner.                                       
               Henry C. Griego, for respondent.                                       

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