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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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