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Estate of N. Jerome Schulman v. Commissioner of Internal Revenue

UNITED STATES COURT OF APPEALS, SECOND CIRCUIT.


June 15, 1979

ESTATE OF N. JEROME SCHULMAN, DECEASED, DORIS G. LEE, FORMERLY KNOWN AS DORIS G. SCHULMAN, EXECUTRIX, PETITIONERS-APPELLANTS
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLEE.

Before MANSFIELD, MULLIGAN and TIMBERS, Circuit Judges.

Upon this appeal by the Estate of N. Jerome Schulman, who died on July 15, 1972, from an order and decision of the United States Tax Court entered October 18, 1978, to the effect that there is due from the Estate to the Internal Revenue Service a Federal estate tax deficiency in the amount of $19,941 arising out of the decedent's October 27, 1970, transfer to his wife in contemplation of death of an accidental death and dismemberment insurance policy which should have been included in the decedent's gross estate under the provisions of ยง 2035 of the Internal Revenue Code of 1954, the order and decision of the Tax Court is

AFFIRMED upon the well-reasoned opinion of Judge Howard A. Dawson, Jr. of the Tax Court filed October 4, 1978.

19790615

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