Rand v. Commissioner
United States Board of Tax Appeals
1. Where neither terms of trust nor state law expressly forbid the use of trust income for payment of life insurance premiums, held, petitioner taxable under section 167(a)(3), Revenue Act of 1934, on trust income used in taxable year to pay life insurance premiums on policies of insurance on his own life; held, further, such tax liability limited to amount of premiums paid or payable out of trust income upon existent policies.
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1. Where neither terms of trust nor state law expressly forbid the use of trust income for payment of life insurance premiums, held, petitioner taxable under section 167(a)(3), Revenue Act of 1934, on trust income used in taxable year to pay life insurance premiums on policies of insurance on his own life; held, further, such tax liability limited to amount of premiums paid or payable out of trust income upon existent policies. Following Genevieve F. Moore,39 B.T.A. 808. 2. Book figures for corporation's assets in prior year, giving substantial value to corporation's stock, held, of no…
1Opinion of the Court
FRANK C. RAND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Rand v. Commissioner
Docket No. 91795.
United States Board of Tax Appeals
40 B.T.A. 233; 1939 BTA LEXIS 876;
July 18, 1939, Promulgated
1. Where neither terms of trust nor state law expressly forbid the use of trust income for payment of life insurance premiums, held, petitioner taxable under section 167(a)(3), Revenue Act of 1934, on trust income used in taxable year to pay life insurance premiums on policies of insurance on his own life; held, further, such tax liability limited to amount of premiums paid or payable out…
2Cases cited7 opinions
- Burnet v. WellsSupreme Court of the United States · 1933
- Morton v. CommissionerUnited States Board of Tax Appeals · 1938
- Cornet v. CornetSupreme Court of Missouri · 1916
- Rand v. CommissionerUnited States Board of Tax Appeals · 1939
- National City Bank v. CommissionerUnited States Board of Tax Appeals · 1937
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