Zimmermann v. Commissioner
United States Tax Court
A $ 3,000 payment was made to petitioner in 1951 out of a fund comprised of the surrender value of an endowment contract and an annuity contract and accumulated interest thereon. The payment was made pursuant to an agreement whereby the insurance company retained the fund at interest of not less than 3 per cent on the unpaid balance, distributed to petitioner $ 3,000 per annum, and reserved to petitioner the right to withdraw all or part of the unpaid balance at any time.
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A $ 3,000 payment was made to petitioner in 1951 out of a fund comprised of the surrender value of an endowment contract and an annuity contract and accumulated interest thereon. The payment was made pursuant to an agreement whereby the insurance company retained the fund at interest of not less than 3 per cent on the unpaid balance, distributed to petitioner $ 3,000 per annum, and reserved to petitioner the right to withdraw all or part of the unpaid balance at any time. The amount of interest credited to the account in 1951 was $ 2,955.03. Held, the payment was not exempt from taxation…
1Opinion of the Court
Phil L. Zimmermann, Petitioner, v. Commissioner of Internal Revenue, Respondent
Zimmermann v. Commissioner
Docket No. 51338
United States Tax Court
25 T.C. 233; 1955 U.S. Tax Ct. LEXIS 60;
October 31, 1955, Filed
Decision will be entered for the respondent.
A $ 3,000 payment was made to petitioner in 1951 out of a fund comprised of the surrender value of an endowment contract and an annuity contract and accumulated interest thereon. The payment was made pursuant to an agreement whereby the insurance company retained the fund at interest of not less than 3 per cent on the unpaid balance, distributed…
2Cases cited17 opinions
- Carr v. HamiltonSupreme Court of the United States · 1889
- Thornley v. Commissioners of Internal RevenueCourt of Appeals for the Third Circuit · 1945
- Thornley v. CommissionerUnited States Tax Court · 1943
- Fleming v. CommissionerUnited States Tax Court · 1955
- Blum v. HigginsCourt of Appeals for the Second Circuit · 1945
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