WILLIAMS, J.
This is a federal estate tax case wherein appellee, Commissioner of Internal Revenue, sought to recover $24,412.84 in estate taxes from appellant, Estate of Mattias Arnold Madsen. A deficiency was noted for failure to include one-half of the proceeds of a $200,000 life insurance policy in the gross estate of Mr. Madsen. The United States Tax Court ruled that one-half of the insurance proceeds were includable in the estate under the Internal Revenue Code...
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