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Commissioner v. Estate of Noel
United States Supreme Court
380 U.S. 678 (1965)
While at the airport with his wife, Mr. Noel bought flight insurance before boarding a plane. Noel’s wife, Ruth (plaintiff), who did not board the plane, paid the premiums and took possession of the policies. Under the terms of the policies, the power to alter beneficiaries or to assign the policies were held by Noel. The plane crashed, Noel died, and Ruth received the face value of the insurance policies. Ruth did not include the amount paid on the policies in Noel’s gross estate. The Internal Revenue Service (IRS) (defendant) determined that the amounts should have been included in the gross estate, and the tax court upheld the IRS’s determination. The court of appeals reversed, and the IRS appealed to the United States Supreme Court.
Rule of Law
Holding and Reasoning (Black, J.)
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