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ESTATE OF TAYLOR v. COMMISSIONER

Docket No. 46890-86.

56 T.C.M. 1498 (1989)

T.C. Memo. 1989-112

Estate of Irving A. Taylor, Deceased, C. Dianne Taylor, Executrix v. Commissioner.

United States Tax Court.

Filed March 22, 1989.

Attorney(s) appearing for the Case

Richard J. Callaway, for the petitioner. Michael J. Calabrese, for the respondent.

Memorandum Opinion

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioner's Federal estate tax of $73,553.39. After concessions the issue we must resolve is whether the United States-Canadian estate tax convention precludes the United States from imposing Federal estate tax on the transfer of certain life insurance proceeds and death benefits from retirement annuity contracts and a retirement plan.

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