O'Donohue v. Commissioner
United States Tax Court
Petitioner, indebted to various creditors in the total amount of $ 160,000 and being pressed for payment, assigned his income and remainder interests in the Rose M. Taylor Trust to a trustee as collateral to secure bonds issued to the creditors by petitioner.
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Petitioner, indebted to various creditors in the total amount of $ 160,000 and being pressed for payment, assigned his income and remainder interests in the Rose M. Taylor Trust to a trustee as collateral to secure bonds issued to the creditors by petitioner. Petitioner's remainder interest in the Rose M. Taylor Trust was subject to divestment and as a part of the collateral for the bonds, the creditors required petitioner to take out and pay the premiums on certain policies of life insurance, which policies were then assigned to the trustee. The policies named petitioner's personal…
1Opinion of the Court
Bruce, Judge:
This proceeding involves deficiencies and additions to tax as follows:
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Petitioner has conceded all issues raised in his petition except the determined deficiencies and additions to tax for the years 1951, 1952, and 1953 under sections 291(a) and 294(d) of the Internal Revenue Code of 1939, resulting from respondent’s disallowance of deductions for life insurance premiums. The sole remaining issues are whether petitioner is entitled to deduct premiums paid in his behalf on life insurance policies covering the life of petitioner, which policies were procured by…
2Cases cited3 opinions
- Commissioner v. AckerSupreme Court of the United States · 1959
- Leslie v. CommissionerUnited States Tax Court · 1946
- Blaess v. CommissionerUnited States Tax Court · 1957
3Cited by15 opinions
- Carbine v. CommissionerUnited States Tax Court · 1984
- Hendrick v. CommissionerUnited States Tax Court · 1961
- Beaton v. CommissionerUnited States Tax Court · 1980
- Breckenridge v. CommissionerUnited States Tax Court · 1983
- Carbine v. CommissionerUnited States Tax Court · 1984
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