COMMISSIONER OF INT. REV. v. KARAGHEUSIAN'S ESTATE

No. 252, Docket 23822.

233 F.2d 197 (1956)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. ESTATE of Miran KARAGHEUSIAN, Walter J. Corno, Leila Karagheusian, and Minot A. Crofoot, Executors, Respondent. ESTATE of Miran KARAGHEUSIAN, Walter J. Corno, Leila Karagheusian, and Minot A. Crofoot, Executors, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided May 7, 1956.


Attorney(s) appearing for the Case

H. Brian Holland, Asst. Atty. Gen. (Lee A. Jackson, Robert N. Anderson, Joseph N. Goetten, Attys., Dept. of Justice, Washington, D. C., on the brief), for Commissioner of Internal Revenue.

Richard H. Appert, Robert W. Martin, New York City (White & Case, New York City, on the brief, of counsel), for Estate of Miran Karagheusian, Walter J. Corno, Leila Karagheusian and Minot A. Crofoot, Executors.

Before FRANK, LUMBARD and WATERMAN, Circuit Judges.


LUMBARD, Circuit Judge.

The question at issue is whether and to what extent the proceeds of an insurance policy on the life of Miran Karagheusian who died October 7, 1948 are includible in the decedent's gross estate under § 811(g) (2) of the Internal Revenue Code of 1939.

The insurance policy which is the subject of the present litigation was issued on December 23, 1927 pursuant to an application by Zabelle Karagheusian, the wife of the decedent. It...

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