Frohlich v. United States

211 F. Supp. 775, 10 A.F.T.R.2d (RIA) 6313, 1962 U.S. Dist. LEXIS 5056
CourtDistrict Court, E.D. Michigan
DecidedNovember 24, 1962
DocketCiv. A. No. 20345
StatusPublished

This text of 211 F. Supp. 775 (Frohlich v. United States) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Frohlich v. United States, 211 F. Supp. 775, 10 A.F.T.R.2d (RIA) 6313, 1962 U.S. Dist. LEXIS 5056 (E.D. Mich. 1962).

Opinion

THORNTON, District Judge.

This is a tax refund ease. Plaintiff seeks recovery of Federal estate taxes which he claims were erroneously assessed and paid. The amount sought to be recovered is $6,459.36.

The facts which furnish the background of this controversy are simple. They are contained in the stipulation of facts filed herein, a copy of which is attached to this opinion. Plaintiff is the executor of the estate of Edward Froh-lich, deceased. In 1920 Edward Froh-lich purchased a policy of insurance from the Guardian Life Insurance Company of America, face amount $25,000.00. In 1925 Edward Frohlich purchased a policy of insurance from the Fidelity Life Insurance Company, face amount $25,-000.00. In 1949 Edward Frohlich transferred, by gift, the ownership of these policies to Edward P. Frohlich, hereinafter referred to as the taxpayer. Premiums on these policies had been paid by Edward Frohlich up until the time of the transfer of ownership. In 1950 Edward Frohlich paid the applicable gift tax. The taxpayer made no premium [776]*776payments except for 1% premiums on the Fidelity policy, credit for which he received in the estate tax computation. There is no dispute here relative to the payment of 1 y2 premiums by the taxpayer. As to both insurance contracts, the taxpayer converted them to paid-up contracts. At the time of the transfer to the taxpayer the Guardian policy had a cash surrender value of $18,771.23 and the Fidelity policy a cash surrender value of $17,320.25. Edward Frohlich, the trans-feror, died January 13, 1952. The issue here for determination is whether the Commissioner, in determining an estate tax deficiency, rightly included the proceeds of these two life insurance policies in the decedent’s gross estate. The statute here applicable is Section 811(g) (2) (A) of the Internal Revenue Code of 1939, as amended, the pertinent parts of which read as follows:

“The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated, except real property situated outside of the United States —.
******
“(g) Proceeds of life insurance
“(1) Receivable by the executor.
To the extent of the amount receivable by the executor as insurance under policies upon the life of the decedent.
“(2) Receivable by other beneficiaries. To the extent of the amount receivable by all other beneficiaries as insurance under policies upon the life of the decedent (A) purchased with premiums, or other consideration, paid directly or indirectly by the decedent, in proportion that the amount so paid by the decedent bears to the total premiums paid for the insurance, or (B) with respect to which the decedent possessed at his death any of the incidents of ownership, exercisable either alone or in conjunction with any other person. * * * ”

It is the contention of the taxpayer that the only proceeds includible are those representing the difference between the cash surrender value of the policies at the time of transfer and the total proceeds received as a result of the death of decedent. The taxpayer argues that the cash surrender value represents property transferred to him over which he thereby acquired control and dominion, that he might have taken the amounts of the cash surrender value in the form of cash and have done as he wished with it. In lieu of cashing in the policies for their cash surrender value he authorized the two insurance companies to convert the policies into paid-up policies.

The Government contends that the facts in this case are squarely within the provision of the statute which includes proceeds such as these as part of a decedent’s gross estate. It relies upon the so-called “payment of premium” test, claiming that decedent paid the premiums, not the taxpayer. There is no problem here with relation to possessing or retaining any of the incidents of ownership. Decedent retained none subsequent to the transfer. The taxpayer received and retained all incidents of ownership.

The parties have filed thorough briefs with the Court and have also presented able argument in support of their respective contentions here. Both sides have indulged in considerable theorizing and review of tax law history (by the Government) and insurance concepts (by plaintiff). We think, however, that the resolution of this issue depends upon the answer to one simple question, albeit the answer is not as simple to arrive at as the question is to pose — -Who paid the premiums on these insurance policies? The statute, in effect, makes this the test. It indicates clearly that no distinction is to be made between direct or indirect payments by the decedent. The taxpayer here contends that he paid the premiums directly (the cash surrender value constituting one lump sum payment for each policy) when he exercised his ownership over the policies and converted [777]*777them into paid-up contracts of insurance. The Government contends that decedent paid the premiums directly, having made premium payments from 1920 as to the Guardian policy and from 1925 as to the Fidelity policy until he transferred the policies in 1949. As a.matter of theory we might well say that both the taxpayer and the Government are right. Certainly, even the taxpayer may not argue that the decedent did not in fact pay premiums from policy inception to policy transfer. Certainly, the Government cannot be heard to say that the taxpayer did not use his cash surrender privilege as payment for paid-up contracts of insurance. Viewing the contention of the taxpayer and that of the Government, each in its strongest and most favorable light, we are confronted with a paradox in attempting to determine, as we must, whether the “insurance under policies upon the life of the decedent” was purchased with premiums paid directly or indirectly by decedent. Fortunately for the Court, it is not necessary to indulge in speculation of either a theoretical or practical nature to come to a conclusion here. , We believe that the Supreme Court has indicated with precision what approach is to be here adopted. We are aware of a number of decisions that we might proceed to dissect here in an effort to make various analogies and distinctions. None that we know of is directly in point apart from the one hereinafter referred to. The opinion of the United States Supreme Court handed down June 13, 1960 in the case of United States v. Manufacturers National Bank of Detroit, 363 U.S. 194, 80 S.Ct. 1103, 4 L.Ed.2d 1158, we consider to be controlling here. That case involved a somewhat similar situation but one where the insured continued to make payments after having transferred ownership of the policies to his wife. This fact was not considered by the court as controlling in its decision that the proceeds were part of the gross estate. The owner there was given full and complete ownership rights, including cash surrender privilege. She did not elect to take such cash but instead allowed her equity in the policy to continue. The continuation of payments by the insured however played no part in the rationale upon which the Supreme Court bottomed its theory of taxable transfer as being directly related to the maturing of a beneficiary’s right to the proceeds, the death of the insured creating a genuine enlargement of the beneficiary’s rights.

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Bluebook (online)
211 F. Supp. 775, 10 A.F.T.R.2d (RIA) 6313, 1962 U.S. Dist. LEXIS 5056, Counsel Stack Legal Research, https://law.counselstack.com/opinion/frohlich-v-united-states-mied-1962.