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ESTATE OF SHIELDS v. COMMISSIONER

Docket No. 110167.

1 T.C.M. 585 (1943)

Estate of Francis H. Shields, Deceased, The Pennsylvania Company for Insurance on Lives and Granting Annuities and Greta Carter Shields, Executors v. Commissioner.

United States Tax Court.

Entered February 11, 1943.

Attorney(s) appearing for the Case

Joseph A. Lamorelle, Esq., 2301 Packard Bldg., Philadelphia, Pa., for the petitioners. Lewis S. Pendleton, Esq., for the respondent.

Memorandum Opinion

HILL, Judge:

The Commissioner determined a deficiency of $823.22 in estate tax. That determination was premised principally upon the inclusion of the proceeds of an insurance policy in the gross estate of decedent. The respondent excluded from the gross estate the income collected during the optional period. Petitioners contend that the proceeds of the insurance policy, which were paid to decedent's wife as beneficiary, should not be included...

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