Seligmann v. Commissioner
United States Tax Court
The taxpayer, beneficiary of a trust to which her husband had transferred insurance policies on his life, paid the premiums on the policies and interest on loans against the policies. Such payments, held, not subject to tax as gifts under section 1000, Internal Revenue Code, being made to protect the taxpayer's own interest.
1Opinion of the Court
OPINION.
Johnson, Judge:
This case was submitted upon a stipulation and exhibits, which we hereby adopt 'as findings of fact and from which it appears that:
Petitioner, a resident of San Antonio, Texas, filed a gift tax return for 1941 with the collector of internal revenue for the first district of Texas. She is the wife of Julius Seligmann, and was designated as beneficiary under three policies of insurance which he took out on his life in 1923 and under six policies which he took out in 1928. The face amount of the nine policies aggregated $185,000. On December 20,1935, Seligmann, with the…
2Cases cited4 opinions
- Burnet v. GuggenheimSupreme Court of the United States · 1933
- Smith v. ShaughnessySupreme Court of the United States · 1943
- Helvering v. HutchingsSupreme Court of the United States · 1941
- Bolton v. CommissionerUnited States Tax Court · 1943
3Cited by12 opinions
- Hart v. CommissionerUnited States Tax Court · 1948
- Estate of Di Marco v. CommissionerUnited States Tax Court · 1986
- Commissioner of Internal Revenue v. BergerCourt of Appeals for the Second Circuit · 1953
- Goodnow v. United StatesUnited States Court of Claims · 1962
- Pleet v. CommissionerUnited States Tax Court · 1951
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