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decedent was neither an accident nor fraudulent but was
deliberately done as part of decedent's estate planning.
Decedent's Federal estate tax return was timely filed on
December 30, 1991, signed by Anne Street Skipper,
coadministratrix. In that return, the estate reported insurance
on decedent's life in the total amount of $1,347,882, but
excluded therefrom $673,941 as representing a one-half community
property share not owned by decedent (but by Mrs. Street).
After trial to a jury, the Texas District Court entered
judgment in August 1993 pursuant to specific questions that had
been put to the jury and answered by it. The judgment
specifically held inter alia that Mrs. Street had no valid claim
against the proceeds of the insurance on decedent's life and that
the estate was entitled to 100 percent thereof. The District
Court also revoked the letters of coadministration previously
issued and issued new letters solely in favor of Anne Street
Skipper. Finally, the court ruled that Mrs. Street take nothing
from her claims, and substantial attorney fees were awarded
against her.
The judgment of the Texas District Court was appealed by
Mrs. Street to the Texas Court of Appeals, and an opinion thereon
was rendered in 1994. Street v. Skipper, 887 S.W.2d 78 (Tex.
App. 1994). In sum, the Court of Appeals affirmed the District
Court on all counts. With specific reference to the proceeds of
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