United States Tax Court February 21, 1955, Docket No. 37909 (Bowers v. Commissioner)

lead-opinion

OPINION.

BRUCE, Judge:

Respondent contends1 that the proceeds of two life insurance policies on decedent’s life which were made available to decedent’s former wife are includible in the gross estate under section 811 (g) (2)2 of the Internal Revenue Code of 1939. Petitioner argues that the proceeds of said policies should not be included in the gross estate.