Does the fact that the wife was designated in the policy as its owner constitute clear and convincing evidence that the husband intended to give his interest to her?

MultiRegion, United States of America

The following excerpt is from Estate of Madsen v. C.I.R., 659 F.2d 897 (9th Cir. 1981):

2 The fact that the wife was designated in the policy as its owner does not, standing alone, constitute clear and convincing evidence that the decedent intended to give his interest to her. There must be additional evidence of decedent's intent to make a gift. Kern v. United States, supra at 439.

3 Wash.Rev.Code 48.18.440(1) reads as follows:

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