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ESTATE OF ROCKWELL v. COMMISSIONER

Docket No. 12150-82.

49 T.C.M. 331 (1984)

T.C. Memo. 1984-654

Estate of Willard F. Rockwell, Deceased, Willard F. Rockwell, Jr., and Mellon Bank, N.A., Executors v. Commissioner.

United States Tax Court.

Filed December 19, 1984.

Attorney(s) appearing for the Case

George R. Craig, 1508 Law & Finance Bldg., Pittsburgh, Pa., for the petitioner, Frank A. Falvo, for the respondent.

Memorandum Opinion

DAWSON, Chief Judge:

Respondent determined a deficiency in Federal estate tax against the Estate of Willard F. Rockwell, deceased, in the amount of $93,877.78.

After concessions by petitioner, the issues remaining for decision are (1) whether decedent retained sufficient incidents of ownership in eight insurance policies on his life to require the proceeds of these policies to be included in his gross estate under section 2042...

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