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ESTATE OF MORRISSETTE v. COMMISSIONER

Docket No. 4415-14.

146 T.C. 171 (2016)

146 T.C. No. 11

ESTATE OF CLARA M. MORRISSETTE, DECEASED, KENNETH MORRISSETTE, DONALD J. MORRISSETTE, AND ARTHUR E. MORRISSETTE, PERSONAL REPRESENTATIVES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 13, 2016.

Attorney(s) appearing for the Case

James Egbert McNair III and Kelley C. Miller , for petitioners.

Warren P. Simonsen and Rachel L. Rollins , for respondent.

OPINION

This matter is before us on a motion for partial summary judgment under Rule 121(a)1 filed by the Estate of Clara M. Morrissette (estate). The issue for decision is whether, for valuation purposes, the split-dollar life insurance arrangements at issue are governed by the economic benefit...

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