- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011