Estate of Skifter v. Commissioner
United States Court of Appeals for the Second Circuit
468 F.2d 699 (1972)
Hector Skifter purchased a number of insurance policies on his life. Skifter then assigned those policies to his wife, Naomi. Naomi died. Pursuant to Naomi’s will, the insurances policies were placed in a trust. Naomi’s daughter, Janet, was the income beneficiary, and several other family members were the remaindermen. Skifter was the trustee and was given discretion to pay the entire corpus of the trust out to Janet at any time. Skifter died, and his estate (plaintiff) did not include the policies in Skifter’s gross estate. The Internal Revenue Service (IRS) (defendant) issued a deficiency against the estate, claiming that Skifter possessed incidents of ownership in the policies that required them to be included in the gross estate. Skifter’s estate prevailed in tax court against the IRS, and the IRS appealed.
Rule of Law
Holding and Reasoning (Lumbard, J.)
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