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ESTATE OF TOWLE v. COMMISSIONER

Docket No. 2142-68.

54 T.C. 368 (1970)

ESTATE OF JANICE McNEAR TOWLE, THE FIRST NATIONAL BANK OF CHICAGO, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 26, 1970.

Attorney(s) appearing for the Case

Charles R. Sprowl and Richard A. Beck, for the petitioner.

Sheldon S. Rosenfeld and Lewis M. Porter, Jr., for the respondent.

OPINION

TANNENWALD, Judge:

Respondent has determined a deficiency in petitioner's estate tax of $27,920.45. The sole issue for our determination is whether the proceeds of certain insurance settlement contracts over which the decedent possessed a power of appointment with the consent of a trustee are excludable from her gross estate.

All of the facts are stipulated and are found accordingly.

Petitioner, the executor of the Estate of...

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