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Taxation-Federal Estate Tax-Transfers Of Life Insurance In Contemplation Of Death, Ralph E. Hunt S. Ed.

Michigan Law Review

Insurance policies on the life of a decedent are ordinarily included in his gross estate according to the provisions of section 811 (g) of the Internal Revenue Code. Where the policy is payable to a beneficiary other than the executor, it is taxable under section 811(g)(2): (1) if the decedent paid premiums on the policy, in proportion to the amount of premiums paid by him in relation to the total premiums paid, or (2) if the decedent possessed at his death any of the incidents of ownership. However, these provisions are not exclusive; even though section 811 (g) is inapplicable, …