ESTATE OF WELLIVER v. COMMISSIONER

Docket No. 8979.

8 T.C. 165 (1947)

ESTATE OF JUDSON C. WELLIVER, DECEASED, BY JANE H. WELLIVER, EXECUTRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated January 28, 1947.


Attorney(s) appearing for the Case

William F. Leopold, Jr., Esq., for the petitioner.

Robert H. Kinderman, Esq., for the respondent.


The Commissioner determined a deficiency of $3,367.49 in estate tax of the decedent's estate, in part by including in the value of the estate the full proceeds of a life insurance policy on which decedent's employer paid a portion of the premiums and by increasing the value of nineteen contracts for the payment of an annuity to his widow. Petitioner contends that the insurance proceeds includible in the estate are only that part thereof proportionate to decedent's contributions...

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