ESTATE OF CROCKER v. COMMISSIONER

Docket No. 88086.

37 T.C. 605 (1962)

ESTATE OF GERTRUDE H. CROCKER, DECEASED, WILLIAM G. PARROTT, JR., ADMINISTRATOR, AND WILLIAM W. CROCKER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 5, 1962.


Attorney(s) appearing for the Case

Franklin C. Latcham, Esq., for the petitioners.

Donald G. Daiker, Esq., for the respondent.


Respondent determined a deficiency in income tax for the year 1955 in the amount of $14,178.67. The issues remaining for decision are (1) whether the petitioners made a bona fide sale of life insurance policies and (2), if so, whether the increment or profit realized upon the sale of these policies is taxable as ordinary income.

FINDINGS OF FACT.

Petitioners are a surviving husband and the estate of his deceased...

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