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ESTATE OF COLEMAN v. COMMISSIONER

Docket No. 4333-68.

52 T.C. 921 (1969)

ESTATE OF INEZ G. COLEMAN, DECEASED, D. C. COLEMAN, JR., EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 9, 1969.

Attorney(s) appearing for the Case

Sydney S. Traum, for the petitioner.

Glen W. Gilson II, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent has asserted a deficiency against petitioner of $20,334.75 in estate tax. The issues for decision are (1) whether the amount to be included in decedent's gross estate under section 20351 should be a prorata portion of the proceeds of insurance on decedent's life or the amount of the premiums conceded to have been paid by the decedent in contemplation of death and (2) whether a potential...

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