Estate of Sprague v. Commissioner

1982 T.C. Memo. 301, 44 T.C.M. 1, 1982 Tax Ct. Memo LEXIS 445
CourtUnited States Tax Court
DecidedJune 1, 1982
DocketDocket No. 16847-79.
StatusUnpublished

This text of 1982 T.C. Memo. 301 (Estate of Sprague v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Sprague v. Commissioner, 1982 T.C. Memo. 301, 44 T.C.M. 1, 1982 Tax Ct. Memo LEXIS 445 (tax 1982).

Opinion

ESTATE OF LAVERN D. SPRAGUE, DECEASED; HELEN J. SPRAGUE PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Sprague v. Commissioner
Docket No. 16847-79.
United States Tax Court
T.C. Memo 1982-301; 1982 Tax Ct. Memo LEXIS 445; 44 T.C.M. (CCH) 1; T.C.M. (RIA) 82301;
June 1, 1982.
J. Michael Traher, for the petitioner.
David W. Otto, for the respondent.

WILES

MEMORANDUM FINDINGS OF FACT AND OPINION

WILES, Judge: Respondent determined a deficiency of $ 6,999 in petitioner's Federal estate tax. The sole issue for decision is whether the decedent's assignment of a group*446 term life insurance policy on his life to his wife approximately 32 months prior to his death was made in contemplation of death within the meaning of section 2035. 1

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly.

Decedent, Lavern D. Sprague, died testate on January 5, 1976, at the age of 66. Decedent's wife, Helen J. Sprague (hereinafter sometimes referred to as Mrs. Sprague), was duly appointed the personal representative of his estate. Helen J. Sprague resided in Tucson, Arizona, at the time the petition was filed in this case. Decedent's Federal estate tax return was filed with the Internal Revenue Service Center, Ogden, Utah.

During his adult life, decedent was a medical doctor, specializing in obstetrics and gynecology. By 1966, decedent became associated with a group of physicians forming the Tucson Clinic (hereinafter the Clinic), a facility providing medical services in Tucson, Arizona. Decedent remained associated with the Tucson Clinic until his death.

In 1966, the Continental Assurance Company*447 (hereinafter Continental) issued a group term life insurance policy (hereinafter sometimes referred to as the Continental policy) covering participants of the Clinic. Decedent was a participant of the Clinic and Continental's policy provided him with $ 50,000 of term life insurance. At all relevant times herein, the Clinic paid the premiums on the Continental policy.

The Continental policy, in addition to providing decedent with $ 50,000 of life insurance, contained a conversion privilege and a special disability benefit. The conversion privilege entitled decedent to convert his group policy into an individual policy of life insurance, "except term insurance," if, inter alia, his employment at the Clinic ceased. The special disability benefit consisted of two parts. First, if decedent became permanently and totally disabled prior to his 60th birthday and while insured under the Continental policy, Continental would pay decedent a fixed number of monthly installments uo to $ 50,000. Second, if decedent became disabled after attaining age 60 but prior to his 65th birthday, and while insured under the Continental policy, then subject to certain conditions, Continental would continue*448 to provide the decedent with term insurance coverage without requiring payment of premiums.

In 1969, decedent and his wife sought the services of Security Planning Service, Inc. (hereinafter SPS), a Tempe, Arizona, company engaged in estate and financial planning services for clients. As a result of their consultations with representatives of SPS, including Donald J. Kenney (hereinafter Kenney), an attorney for Security, the following actions were taken by the Spragues during 1970: purchase of mortgages and gas and drilling investments; creation of a revocable living trust (hereinafter sometimes referred to as the revocable trust agreement); execution of last wills and testaments for decedent and his wife.

On November 14, 1970, the Spragues executed the revocable trust agreement, and planned to transfer much of their community property to this trust in order to avoid probate and to save estate taxes. Decedent was the trustee of the revocable trust.

In a letter that Kenney sent to decedent and his wife he stated, in pertinent part, that the Spragues' "estate plan" would achieve the following goals:

A. First, by a Trust of this type [i.e., the revocable trust] we are able*449 to avoid the necessity of probate upon the death of the first spouse and the second spouse and the property will pass to the successor Trustee who upon the death of the second spouse will distribute it to your children pursuant to your request. By avoiding probate you are able to save approximately 10% of your estate upon the death of each spouse these costs which are saved include, court costs, attorneys fees, executor's commission which in Arizona approximate 10% of the probate estate. In addition by avoiding probate you avoid the necessity of having your property tied up for several months or even years, further, you avoid the necessity of having the Court approve any transfer or sale of property which would be necessary in the event a probate were necessary.

B. Secondly, through a Trust of this type substantial estate tax savings will be realized upon the death of the second spouse. The reason for this is that the Trust retains the estate splitting benefits which you have upon the death of the first spouse under the community property laws of the State of Arizona. This means that upon the death of the first spouse due to community property only one-half of the estate is taxed*450 but if you do not have a Trust of this type the entire estate would be subject to taxation upon the death of the second spouse. Through this Trust the estate remains split and only one-half of the estate will be taxed upon the second spouse's death. In this regard one caution to be aware of is that these instruments are prepared with the assumption that the husband will die first which statistics show occur in probably 80% of the cases.

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Related

United States v. Wells
283 U.S. 102 (Supreme Court, 1931)
Allen v. Trust Co. of Ga.
326 U.S. 630 (Supreme Court, 1946)
Landorf v. United States
408 F.2d 461 (Court of Claims, 1969)
Bel v. United States
452 F.2d 683 (Fifth Circuit, 1971)

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Bluebook (online)
1982 T.C. Memo. 301, 44 T.C.M. 1, 1982 Tax Ct. Memo LEXIS 445, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-sprague-v-commissioner-tax-1982.