ESTATE OF TOMERLIN v. COMMISSIONER

Docket No. 704-83.

51 T.C.M. 831 (1986)

T.C. Memo. 1986-147

Estate of James O. Tomerlin, William R. Tomerlin, Executor v. Commissioner.

United States Tax Court.

Filed April 15, 1986.


Attorney(s) appearing for the Case

Douglas M. Edwards, for the petitioner. A. Chris Zimmerman, for the respondent.


Memorandum Opinion

STERRETT, Chief Judge:

By notice of deficiency dated October 6, 1982, respondent determined a deficiency of $138,346 in the Federal estate tax of the Estate of James O. Tomerlin. After concessions, the sole issue for our resolution is whether decedent possessed any incidents of ownership in a life insurance policy on decedent's life, thereby warranting the inclusion of the proceeds of said policy in decedent's gross estate pursuant to...

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