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ESTATE OF PERRY v. COMMISSIONER

Docket No. 4132-88.

59 T.C.M. 65 (1990)

T.C. Memo. 1990-123

Estate of Frank Martin Perry, Sr., Deceased, Michael C. Perry, Whit S. Perry, and Robert S. Perry, Co-Executors v. Commissioner.

United States Tax Court.

Filed March 8, 1990.

Attorney(s) appearing for the Case

Hugh C. Montgomery, Jr., David P. Webb, and Charles L. Brocato, 210 E. Capitol Street, Jackson, Miss., for the petitioner. J. Craig Young and Helen C.T. Smith, for the respondent.

Memorandum Opinion

COHEN, Judge:

Respondent determined a deficiency of $320,957 in the Federal estate tax of the estate of Frank Martin Perry, Sr., deceased, Michael C. Perry, Whit S. Perry, and Robert S. Perry, co-executors. After concessions, the sole issue for decision is whether proceeds totaling $600,000 from life insurance policies purchased within 3 years of decedent's death are includable in decedent's gross estate pursuant to section 2035(a). The...

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