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PIGGOTT'S ESTATE v. C. I. R.

No. 15457.

340 F.2d 829 (1965)

ESTATE of Grant H. PIGGOTT, Deceased, David S. Piggott and Albert F. Piggott, Co-Administrators, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

February 4, 1965.

Attorney(s) appearing for the Case

John L. King, Detroit Mich. (Berry, Moorman & King, Detroit, Mich., on the brief), for petitioners.

Edward B. Greensfelder, Jr., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, David O. Walter, Edward B. Greensfelder, Jr., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before MILLER, O'SULLIVAN and PHILLIPS, Circuit Judges.

SHACKELFORD MILLER, Jr., Circuit Judge.

This case involves the liability of the estate of Grant H. Piggott, deceased, under the Federal Estate Tax with respect to the proceeds of an insurance policy on his life payable to his corporate employer, who paid the annual premiums called for by the policy and who had possession of the policy at the time of the decedent's death. The Tax Court held the proceeds were includable in the gross estate of the decedent for Federal...

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