Johnson v. Commissioner
United States Tax Court
J and C formed a partnership, and J purchased insurance on the life of C to protect his investment. C died, and partnership assets were distributed to C's widow in exchange for her assumption of a debt of the partnership. Held, any loss subsequently arising in connection with such partnership assets was not sustained by the partnership and J's loss was of his investment in the partnership.
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J and C formed a partnership, and J purchased insurance on the life of C to protect his investment. C died, and partnership assets were distributed to C's widow in exchange for her assumption of a debt of the partnership. Held, any loss subsequently arising in connection with such partnership assets was not sustained by the partnership and J's loss was of his investment in the partnership. Held, further, the life insurance proceeds compensated J for his loss within the meaning of sec. 165(a), I.R.C. 1954.
1Opinion of the Court
Alson N. Johnson and Margaret C. Johnson, Petitioners v. Commissioner of Internal Revenue, Respondent
Johnson v. Commissioner
Docket No. 5916-73
United States Tax Court
66 T.C. 897; 1976 U.S. Tax Ct. LEXIS 56;
August 24, 1976, Filed
Decision will be entered for the respondent.
J and C formed a partnership, and J purchased insurance on the life of C to protect his investment. C died, and partnership assets were distributed to C's widow in exchange for her assumption of a debt of the partnership. Held, any loss subsequently arising in connection with such partnership assets was not sustained by the…
2Cases cited12 opinions
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- Putoma Corp. v. CommissionerUnited States Tax Court · 1976
- Louis Spitalny and Betty Spitalny, His Wife v. United States of America, William Erdwurm and Bart F. Erdwurm, His Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
- Fox v. CommissionerUnited States Tax Court · 1968
- Estate of Munter v. CommissionerUnited States Tax Court · 1975
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