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ESTATE OF MUDGE v. COMMISSIONER

Docket No. 51443.

27 T.C. 188 (1956)

ESTATE OF EDMUND W. MUDGE, LEONARD S. MUDGE AND FIDELITY TRUST COMPANY, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 31, 1956.

Attorney(s) appearing for the Case

Lee W. Eckels, Esq., and Henry A. Morrow, Jr., Esq., for the petitioners.

Roy E. Graham, Esq., for the respondent.

Respondent determined a deficiency of $698,513.04 in estate tax, only part of which has been placed in issue. The only question remaining is whether the corpus of a life insurance trust is to be included in decedent's gross estate either as a transfer in contemplation of death or as property with respect to which decedent possessed incidents of ownership.

FINDINGS OF FACT.

Some of the facts have been stipulated and...

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