TAXATION - ANNUITY CONTRACTS - FEDERAL ESTATE TAX
O'Laughlin, Charles J.
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Abstract
The decedent purchased several single-premium annuity contracts, the annuity payments to be made to her for life, and after her death to a designated second annuitant for life. The Board of Tax Appeals ruled that the policy should not be taxed as a transfer to take effect at death. Held, on appeal, the interest passing to the second anuitant at the death of the decedent should be included in decedent's gross estate under the federal estate tax, since it falls within the provision taxing transfers intended to take effect in possession and enjoyment at or after the death of the transferor. Commissioner v. Clise, (C. C. A. 9th, 1941) 122 F. (2d) 998.