Thompson v. Commissioner
United States Tax Court
1. Petitioner was the sole beneficiary of two policies of insurance totaling $ 75,000 on the life of her deceased husband. The policies were pledged to a trust company as collateral security for debts of her husband totaling $ 33,194.91, evidenced by notes signed by petitioner as an accommodation party. Petitioner herself paid part of the debts and the balance was paid out of the proceeds of the policies.
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1. Petitioner was the sole beneficiary of two policies of insurance totaling $ 75,000 on the life of her deceased husband. The policies were pledged to a trust company as collateral security for debts of her husband totaling $ 33,194.91, evidenced by notes signed by petitioner as an accommodation party. Petitioner herself paid part of the debts and the balance was paid out of the proceeds of the policies. Petitioner received an assignment from the trust company of its claim against the estate. She also paid $ 15,440.65 for all other outstanding claims against the estate and became the sole…
1Opinion of the Court
OPINION.
FisheR, Judge:
At various times, when the value of the assets of decedent’s estate available for the payment of claims did not exceed $26,413.05 (cash in the amount of $3,923.05 and securities of a fair market value not in excess of $22,490), petitioner acquired claims against the estate totaling somewhat in excess of $48,635.56. The amount by which the claims exceeded the above total figure arises from the fact (here immaterial) that some of the smaller claims were purchased for amounts less than their face value. One claim, in the amount of $33,194.91, is attributable to petitioner’s…
2Cases cited4 opinions
- Shiman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- American Cigar Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
- Hoyt v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
- Houk v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1949
3Cited by23 opinions
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- C. M. Gooch Lumber Sales Co. v. CommissionerUnited States Tax Court · 1968
- Arrigoni v. CommissionerUnited States Tax Court · 1980
- Hudlow v. CommissionerUnited States Tax Court · 1971
- Martin v. CommissionerUnited States Tax Court · 1962
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