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ESTATE OF THOMPSON v. COMMISSIONER

Docket No. 4795-79.

41 T.C.M. 1333 (1981)

T.C. Memo. 1981-200

Estate of Gordon E. Thompson, Jr., Deceased, L. Hayes Tate and Southeast Banks Trust Company, N.A., Co-Personal Representatives v. Commissioner.

United States Tax Court.

Filed April 23, 1981.

Attorney(s) appearing for the Case

Lloyd T. Asbury and James D. O'Donnell, Suite 2207 Independent Square, Jacksonville, Fla., for the petitioner. Thomas K. Purcell, for the respondent.

Memorandum Findings of Fact and Opinion

STERRETT, Judge:

By notice of deficiency dated January 16, 1979, respondent determined a deficiency of $112,382 in the Federal estate tax of petitioner. After concessions, the issues are: (1) whether decedent possessed any incidents of ownership in a life insurance policy on decedent's life by virtue of an alleged agreement between decedent and Gordon Thompson Chevrolet, Inc., thereby warranting the inclusion of the...

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