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ESTATE OF CHAPIN v. COMMISSIONER

Docket No. 3340-66,

29 T.C.M. 11 (1970)

T.C. Memo. 1970-7

Estate of William C. Chapin, by Lincoln Rochester Trust Company, Executor v. Commissioner.

United States Tax Court.

Filed January 12, 1970.

Attorney(s) appearing for the Case

Julian M. Fitch, 910 Union Trust Bldg., Rochester, N. Y., for the petitioner. Ferdinand J. Lotz, III, for the respondent.

Memorandum Findings of Fact and Opinion

IRWIN, Judge:

Respondent determined a deficiency of $35,384.51 in the estate taxes of the Estate of William C. Chapin. Petitioner agreed to all of respondent's adjustments except the inclusion in the decedent's estate of $208,528.67 as proceeds from an insurance policy on the life of the decedent.

Three issues are left for our determination. First, we must decide whether a premium payment covering the first...

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