Estate of William G. Street, Deceased, Anne Street Skipper, Executrix - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               K�RNER, Judge:  By notice of deficiency dated October 12,              
          1994, respondent determined a deficiency in the Federal estate              
          tax of the Estate of William G. Street, deceased, Anne Street               
          Skipper, Executrix, in the amount of $157,281.  In the petition             
          that was filed herein, various of respondent's determinations               
          were contested, and claim was made for a refund of certain estate           
          tax payments as being overpayments.  As a result of extensive               
          stipulations of fact and of settled issues entered into by the              
          parties, all such disputes have been resolved except one, which             
          remains for us to decide.  That remaining question is:  where               
          decedent William G. Street purchased life insurance during his              
          life which was community property, and thereafter, during his               
          spouse's life, designated his estate as beneficiary of the                  
          insurance proceeds, was one-half of the proceeds of said                    
          insurance policies excludable from decedent's gross estate as               
          community property that belonged to decedent's wife?                        
               By stipulation of the parties, the case was submitted under            
          Rule 122.  All statutory references are to the Internal Revenue             
          Code in effect as of the date of decedent's death, and all Rule             
          references are to the Tax Court Rules of Practice and Procedure.            

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