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ESTATE OF KURIHARA v. COMMISSIONER

Docket No. 10402-81.

82 T.C. 51 (1984)

ESTATE OF TETSUO KURIHARA, DECEASED, ELEANORE KURIHARA, ADMINISTRATRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 5, 1984.

Attorney(s) appearing for the Case

Ronald Dreier, for the petitioner.

Patrick E. Whelan, for the respondent.

OPINION

TANNENWALD, Judge:

Respondent determined a deficiency of $317,513.19 in petitioner's Federal estate tax. The sole issue for decision is whether petitioner's gross estate includes, pursuant to the provisions of section 2035,1 the proceeds of an insurance policy on decedent's life owned by a trust where decedent gave the trustees the money earmarked for the payment of the initial premium on the policy.

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