Carbine v. Commissioner
United States Tax Court
T, a minority stockholder of BCA, was not only a guarantor of a note given by BCA to a bank but he had also put up his own securities as collateral. To secure the note further, BCA obtained an insurance policy on T's life, and, as owner, assigned it to the bank. As a result of financial difficulties, BCA became unable to pay the premiums in full and meet its other obligations to the bank.
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T, a minority stockholder of BCA, was not only a guarantor of a note given by BCA to a bank but he had also put up his own securities as collateral. To secure the note further, BCA obtained an insurance policy on T's life, and, as owner, assigned it to the bank. As a result of financial difficulties, BCA became unable to pay the premiums in full and meet its other obligations to the bank. T, thereupon, paid those portions of the premiums in 1977 and 1978 that remained unpaid by BCA. T's purpose in making such payments was to protect his securities which had been put up as collateral with the…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax in the amounts of $12,937.90 and $2,354.41 for 1977 and 1978, respectively. After concessions, the sole issue for decision is whether petitioners may deduct premiums paid with respect to an insurance policy on the life of petitioner John D. Carbine. The case was submitted on the basis of a stipulation of facts.
Petitioners John D. Carbine (sometimes hereinafter referred to as petitioner or Carbine) and Eleanor W. Carbine, husband and wife, resided in Haines City, FL, when they filed their petition…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Lohrke v. CommissionerUnited States Tax Court · 1967
17 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- John D. Carbine and Eleanor W. Carbine v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Boomershine v. CommissionerUnited States Tax Court · 1987
- Rice v. CommissionerUnited States Tax Court · 1994
- Sherrer v. Comm'rUnited States Tax Court · 2011
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