Estate of Lumpkin v. Commissioner

474 F.2d 1092 (1973)

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Estate of Lumpkin v. Commissioner

United States Court of Appeals for the Fifth Circuit
474 F.2d 1092 (1973)

Facts

James H. Lumpkin, Jr., was insured through his employer, which provided a group term life-insurance policy for all its employees. The employer dictated that the beneficiaries of the life-insurance policy were an employee’s surviving spouse, minor children, or parents, in that order. Lumpkin could not change the beneficiaries. Lumpkin could, however, defer distributions of the life-insurance proceeds, or otherwise negotiate the timing of distributions with the employer and insurance provider. After Lumpkin’s death, Lumpkin’s estate (plaintiff) did not include the proceeds of the life-insurance policy in Lumpkin’s gross estate when filing the estate-tax return. The Internal Revenue Service (IRS) (defendant) determined that the estate was deficient for estate taxes because it should have included the proceeds of the life-insurance policy. The estate petitioned for a redetermination of the taxes with the United States Tax Court, and that court found that the life-insurance proceeds did not need to be included in the gross estate. The IRS appealed.

Rule of Law

Issue

Holding and Reasoning (Gewin, J.)

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