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ESTATE OF LOEB v. COMMISSIONER

Docket No. 60154.

29 T.C. 22 (1957)

ESTATE OF CLARENCE H. LOEB, DECEASED, BESSIE ROBINSON LOEB, ISIDORE ROBINSON AND HARRY ROBINSON, EXECUTORS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 11, 1957.

Attorney(s) appearing for the Case

Morris J. Oppenheim, Esq., for the petitioners.

John F. Walsh, Esq., for the respondent.

TIETJENS, Judge.

The Commissioner determined a deficiency in estate tax in the amount of $5,339.15 and made an addition to the tax for failure to file a return within the time prescribed by law (sec. 3612 (d), I. R. C. 1939) in the amount of $266.96. Only one of the Commissioner's adjustments is contested. We must decide whether the premiums on life insurance policies on the life of the decedent were indirectly paid by the decedent and the insurance proceeds...

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