Legal Opinion

Fisher v. Commissioner

United States Tax Court

Decided June 9, 1949No. Docket No. 15634Published

Payments to petitioner to continue for her life and resulting from surrender during his lifetime of insurance policies on her husband's life of which she was beneficiary, held annuities which respondent did not err in taxing to her under the 3 per cent annuity provision of Internal Revenue Code, section 22 (b) (2).

1Opinion of the Court

Burtha M. Fisher, Petitioner, v. Commissioner of Internal Revenue, Respondent

Fisher v. Commissioner

Docket No. 15634

United States Tax Court

12 T.C. 1028; 1949 U.S. Tax Ct. LEXIS 172;

June 9, 1949, Promulgated

Decision will be entered for the respondent.

Payments to petitioner to continue for her life and resulting from surrender during his lifetime of insurance policies on her husband's life of which she was beneficiary, held annuities which respondent did not err in taxing to her under the 3 per cent annuity provision of Internal Revenue Code, section 22 (b) (2).

R. M. O'Hara, Esq., and Benjamin…

2Cases cited7 opinions

  1. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  2. Burnet v. WhitehouseSupreme Court of the United States · 1931
  3. Thornley v. CommissionerUnited States Tax Court · 1943
  4. Igleheart v. CommissionerUnited States Tax Court · 1948
  5. Shelley v. CommissionerUnited States Tax Court · 1948

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