ESTATE OF GWINN v. COMMISSIONER

Docket No. 48095.

25 T.C. 31 (1955)

ESTATE OF D. BYRD GWINN, DECEASED, JAMES A. GWINN, ADMINISTRATOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 18, 1955.


Attorney(s) appearing for the Case

L. E. Woods, Jr., Esq., and Robert K. Emerson, Esq., for the petitioner.

Alvin J. Ivers, Esq., for the respondent.


This proceeding involves a deficiency which the Commissioner has determined in estate tax in the amount of $21,657.42 of which approximately $13,143.17 is in dispute.

The issues for decision are:

1. What was the value at the time of the death of the decedent of 360 shares of stock in Gwinn Bros. & Co.?

2. Do the proceeds of a life insurance policy which was pledged with a creditor as collateral security for an indebtedness of decedent qualify for...

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