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ESTATE OF PYLE v. COMMISSIONER

Docket No. 79523.

36 T.C. 1017 (1961)

ESTATE OF IDA JARVIS PYLE, ROBERT M. PYLE, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 14, 1961.

Attorney(s) appearing for the Case

Arthur L. Nims III, Esq., for the petitioner.

Sheldon Seevak, Esq., for the respondent.

OPINION.

FAY, Judge:

The Commissioner has determined a deficiency of $19,504.46 in estate tax.

The only issue to be decided is whether the proceeds of a life insurance policy owned by the decedent, Ida Jarvis Pyle (hereinafter referred to as Ida), on the life of her husband, Wallace Pyle (hereinafter referred to as Wallace), which proceeds on the death of Wallace were left with the insurance company under a settlement option executed by Ida...

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