Heffelfinger v. Commissioner
United States Board of Tax Appeals
1. Section 219(h), Revenue Acts of 1924 and 1926, and section 167, Revenue Act of 1928, providing for the inclusion in the computation of the net income of the grantor of a trust of any part of the income of the trust which is or may be applied to the payment of premiums upon policies of insurance on the life of the grantor, make no distinction either between endowment policies and other kinds of policies, or between that part of a particular premium which equals the cost of…
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1. Section 219(h), Revenue Acts of 1924 and 1926, and section 167, Revenue Act of 1928, providing for the inclusion in the computation of the net income of the grantor of a trust of any part of the income of the trust which is or may be applied to the payment of premiums upon policies of insurance on the life of the grantor, make no distinction either between endowment policies and other kinds of policies, or between that part of a particular premium which equals the cost of protection and the excess paid over that amount, which excess may represent an investment. 2. Where the grantor of two…
1Opinion of the Court
*1233OPINION.
Mtjkdock:
The deficiencies determined by the Commissioner and the appropriate docket numbers are shown in the following table:
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The cases were consolidated for hearing and a stipulation was filed which settled some of the original issues and set forth the facts upon which others were to be decided. The petitioner has stated that the issues raised by him have been settled except for the question of “ whether or not any part of the income of a trust created by the petitioner on December 80, 1922 is taxable to the petitioner.” Since all of the facts relating to that issue have…
2Cases cited5 opinions
- Burnet v. WellsSupreme Court of the United States · 1933
- Carr v. HamiltonSupreme Court of the United States · 1889
- Briggs v. McCulloughCalifornia Supreme Court · 1869
- State ex rel. Clapp v. Federal Investment Co.Supreme Court of Minnesota · 1892
- Endowment & Benevolent Ass'n v. StateSupreme Court of Kansas · 1886
3Cited by5 opinions
- Porto Rico Telephone Co. v. DescartesSupreme Court of Puerto Rico · 1957
- Harris v. CommissionerUnited States Tax Court · 1977
- Heffelfinger v. CommissionerUnited States Board of Tax Appeals · 1935
- Journal Co. v. CommissionerUnited States Board of Tax Appeals · 1942
- Porto Rico Telephone Co. v. DescartesSupreme Court of Puerto Rico · 1957