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ESTATE OF HEADRICK v. COMMISSIONER

Docket No. 21659-86.

93 T.C. 171 (1989)

ESTATE OF EDDIE L. HEADRICK, DECEASED, CLEVELAND BANK & TRUST COMPANY AND CHARLES L. ALMOND, EXECUTORS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 7, 1989.

Attorney(s) appearing for the Case

Robert L. McMurray, for the petitioners.

Edsel Ford Holman, Jr., for the respondent.

NIMS, Chief Judge:

Respondent determined a deficiency in petitioners' Federal estate tax liability of $192,881.15. The issue for decision is whether the proceeds of a life insurance policy purchased within 3 years of the decedent's death by a trust established by the decedent are properly includable in the decedent's gross estate under section 2035(a). (All section references are to sections of the Internal Revenue Code or the Estate Tax Regulations, as the...

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