Estate of William G. Street, Deceased, Anne Street Skipper, Executrix - Page 7

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               Mrs. Street filed an Application for Writ of Error to the              
          Supreme Court of Texas from the Court of Appeals, but that                  
          application was denied by the Supreme Court, which also over-               
          ruled Mrs. Street's motion for rehearing of the application in              
          February 1995.  On the case presented, the judgment of the Texas            
          court has become final.                                                     
               In the notice of deficiency herein, respondent determined              
          that the exclusion of one-half the life insurance proceeds, as              
          reported by the estate, was improper, and that the full amount of           
          $1,347,882 was includable in decedent's gross estate under                  
          section 2042.                                                               
               In the case now before us, petitioner urges that 50 percent            
          of the life insurance proceeds was excludable from the gross                
          estate of decedent, that portion allegedly being the community              
          property of Mrs. Street, who was the survivor.                              
               In the State court actions mentioned above in our findings             
          of fact, Anne Street Skipper, decedent's executrix, prevailed               
          over the claims of Amma Elnora Street and secured a judgment that           
          decedent's estate was entitled to 100 percent of the life                   
          insurance proceeds, as decedent had designated during his                   
          lifetime.  Despite that victory, Anne Street Skipper, executrix,            
          claims here that only one-half of the insurance proceeds should             
          be reported in decedent's gross estate for Federal estate tax               

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