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ESTATE OF HEADRICK v. C.I.R.

No. 90-1150.

918 F.2d 1263 (1990)

ESTATE OF Eddie L. HEADRICK, Cleveland Bank and Trust Company and Charles L. Almond, Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided November 19, 1990.

Attorney(s) appearing for the Case

Robert Lee McMurray (argued), Bell, Painter, McMurray, Cleveland, Tenn., for petitioners-appellees.

Peter K. Scott, I.R.S., Gary R. Allen, Acting Chief, Robert S. Pomerance (argued), John A. Dudeck, Shirley D. Peterson, U.S. Dept. of Justice, Appellate Section Tax Div., Washington, D.C., for respondent-appellant.

Before MILBURN, BOGGS and SUHRHEINRICH, Circuit Judges.

MILBURN, Circuit Judge.

The Commissioner of Internal Revenue appeals the decision of the United States Tax Court holding that the proceeds from an insurance policy are not includable in the gross estate of the decedent, Eddie L. Headrick. For the reasons that follow, we affirm.

I.

Eddie L. Headrick was a tax attorney in Cleveland, Tennessee.1 As part of his personal estate planning, Headrick drafted an irrevocable trust...

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