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ESTATE OF BLOCH v. COMMISSIONER

Docket No. 2667-78.

78 T.C. 850 (1982)

ESTATE OF HARRY BLOCH, JR., DECEASED, FIRST WISCONSIN TRUST COMPANY, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 25, 1982.

Attorney(s) appearing for the Case

Gerald J. Kahn, for the petitioner.

Edward J. Roepsch, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $419,942.46 in petitioner's estate tax. After concessions by the parties, the only issue remaining for decision is whether decedent, who was trustee of a trust created by his father, possessed at the time of his death any "incidents of ownership" in three entrusted insurance policies on his life with the result that the insurance...

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