Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $18,988.43 by including the entire proceeds of nine policies of insurance in the gross estate under section 811 of the Internal Revenue Code. The petitioners allege that it was error to include any more than the proportionate amount which they returned on the basis of premiums paid by the decedent after January 10, 1941. The only other adjustment made by the Commissioner resulted...
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