Legal Opinion

Glassner v. Commissioner

United States Tax Court

Decided February 19, 1965No. Docket No. 1722-63Published

Held, that payments made by Glassner in 1958, 1959, and 1960, pursuant to his written agreements to secure creditors Gerhardt and Goodman by obtaining certain life insurance policies on his life and paying the premiums thereon, are not deductible because Glassner was "directly or indirectly" benefited by the payments within the meaning of section 264(a)(1), I.R.C. 1954. Glassner's estate would have benefited if he had died, since the proceeds of the policies would have…

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Held, that payments made by Glassner in 1958, 1959, and 1960, pursuant to his written agreements to secure creditors Gerhardt and Goodman by obtaining certain life insurance policies on his life and paying the premiums thereon, are not deductible because Glassner was "directly or indirectly" benefited by the payments within the meaning of section 264(a)(1), I.R.C. 1954. Glassner's estate would have benefited if he had died, since the proceeds of the policies would have reduced the debts to the two creditors. Whether the premium payments otherwise qualified as a deductible business, or any…

1Opinion of the Court

Richard M. Glassner and Sylvia B. Glassner, Petitioners, v. Commissioner of Internal Revenue, Respondent

Glassner v. Commissioner

Docket No. 1722-63

United States Tax Court

43 T.C. 713; 1965 U.S. Tax Ct. LEXIS 124;

February 19, 1965

Decision will be entered for the respondent.

Held, that payments made by Glassner in 1958, 1959, and 1960, pursuant to his written agreements to secure creditors Gerhardt and Goodman by obtaining certain life insurance policies on his life and paying the premiums thereon, are not deductible because Glassner was "directly or indirectly" benefited by the payments within…

2Cases cited8 opinions

  1. Rieck v. HeinerCourt of Appeals for the Third Circuit · 1928
  2. Klein v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1936
  3. Klein v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Glassner v. CommissionerUnited States Tax Court · 1965
  5. Parker v. CommissionerUnited States Board of Tax Appeals · 1928

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