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COMMISSIONER v. NOEL ESTATE

No. 503.

380 U.S. 678 (1965)

COMMISSIONER OF INTERNAL REVENUE v. ESTATE OF NOEL ET AL.

Supreme Court of United States.

Decided April 29, 1965.

Attorney(s) appearing for the Case

John B. Jones, Jr., argued the cause for petitioner. With him on the brief were Solicitor General Cox and Assistant Attorney General Oberdorfer.

Harry Norman Ball argued the cause for respondents. With him on the brief was Edward F. Merrey, Jr.

MR. JUSTICE BLACK delivered the opinion of the Court.

This is a federal estate tax case, raising questions under § 2042 (2) of the Internal Revenue Code of 1954, 26 U. S. C. § 2042 (2) (1958 ed.), which requires inclusion in the gross estate of a decedent of amounts received by beneficiaries other than the executor from "insurance under policies on the life of the decedent" if the decedent "possessed at his death...

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