Legal Opinion

Salley v. Commissioner

United States Tax Court

Decided April 10, 1962No. Docket Nos. 66155, 84860UnpublishedCited by 1 opinion

Held, amounts paid to an insurance company in 1954, 1955, and 1956 in the form of interest on purported annuity policy loans are not deductible. Knetsch v. United States, 364 U.S. 361 (1960), followed.

1Opinion of the Court

Rufus C. Salley and Beulah S. Salley v. Commissioner.

Salley v. Commissioner

Docket Nos. 66155, 84860.

United States Tax Court

T.C. Memo 1962-80; 1962 Tax Ct. Memo LEXIS 227; 21 T.C.M. (CCH) 412; T.C.M. (RIA) 62080;

April 10, 1962

Held, amounts paid to an insurance company in 1954, 1955, and 1956 in the form of interest on purported annuity policy loans are not deductible. Knetsch v. United States, 364 U.S. 361 (1960), followed.

Douglas W. McGregor, Esq., for the petitioners. Harold Friedman, Esq., for the respondent.

BLACK

Memorandum Findings of Fact and Opinion

Respondent determined deficiencies in…

2Cases cited4 opinions

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Knetsch v. United StatesSupreme Court of the United States · 1960
  3. Commissioner of Int. Rev. v. Longhorn Portland Cem. Co.Court of Appeals for the Fifth Circuit · 1945
  4. Collins v. CommissionerUnited States Tax Court · 1952

3Cited by1 opinion

  1. Henry C. Minchin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964

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