Genshaft v. Commissioner
United States Tax Court
Held, petitioners must include in their gross income the value of the economic benefit received from the maintenance of certain whole life insurance policies by their family-owned corporation under a so-called "split-dollar" arrangement. Held, further, value determined through application of Rev. Rul. 55-713, 1955-2 C.B. 23. See Rev. Rul. 64-328, 1964-2 C.B. 11.
1Opinion of the Court
OPINION
Irwin, Judge:
Respondent determined deficiencies in petitioners’ income taxes as follows:
Petitioner Docket No. Year Deficiency
Arthur and Leona Genshaft- 9275-72 1968 $11,084.63
1969 12,354.10
David and Anne Genshaft- 9276-72 1968 6,086.01
1969 6,450.96
The sole issue presented is whether petitioners received an economic benefit from the maintenance of certain whole life insurance policies by their family-owned corporation under a so-called “split-dollar” arrangement which is taxable under section 61.1
All of the facts have been stipulated and are found accordingly.
Petitioners Arthur and…
2Cases cited10 opinions
- Commissioner v. SmithSupreme Court of the United States · 1945
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Aetna Life Insurance v. DunkenSupreme Court of the United States · 1925
- Sandor v. CommissionerUnited States Tax Court · 1974
- Dean v. CommissionerUnited States Tax Court · 1961
5 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Greenspun v. CommissionerUnited States Tax Court · 1979
- Johnson v. CommissionerUnited States Tax Court · 1980
- Estate of Dimen v. CommissionerUnited States Tax Court · 1979
- Estate of Dimen v. CommissionerUnited States Tax Court · 1979
- Genshaft v. CommissionerUnited States Tax Court · 1975
4 more not listed; retrieve them via the Exa API.