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ESTATE OF BARATTA-LORTON v. COMMISSIONER

Docket No. 16711-82.

49 T.C.M. 770 (1985)

T.C. Memo. 1985-72

Estate of Mary Baratta-Lorton, Deceased, Robert Baratta-Lorton, Executor v. Commissioner.

United States Tax Court.

Filed February 20, 1985.

Attorney(s) appearing for the Case

Raymond N. Bolton, 105 14th St., Oakland, Calif., for the petitioner. Eugene H. Ciranni and Claire Priestly-Cady, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency of $45,520 in Federal estate tax against the Estate of Mary Baratta-Lorton, deceased. After concession by petitioner, the issues for decision are as follows:

(1) Did the decedent possess a community property interest in a term life insurance policy on her life (of which her husband was the owner and beneficiary), which, if answered in the affirmative, would...

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