Rev. Rul. 72-167

Section 20.2042-1(c)(2) of the Estate Tax Regulations is being reconsidered insofar as it includes within the term "incidents of ownership" a power to change the beneficiary reserved to a corporation of which the decedent is a stockholder. Because of such reconsideration, Revenue Ruling 71-463, C.B. 1971-2, 333, is withdrawn. That Ruling holds that the amount of the proceeds of a life insurance policy owned by a closely-held corporation controlled by the insured-decedent through ownership of a majority of its stock is includible in the decedent's gross estate.

¹ Also released as Technical Information Release 1153, dated March 16, 1972.