Vanderlip v. Commissioner
United States Tax Court
Decedent prior to 1918 took out certain policies of life insurance upon his own life. In 1932 he irrevocably assigned these policies to trustees who were to collect the proceeds at his death and hold them for the benefit of his wife, children, and grandchildren. Before transferring these policies to the trustees decedent borrowed upon them their maximum loan value.
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Decedent prior to 1918 took out certain policies of life insurance upon his own life. In 1932 he irrevocably assigned these policies to trustees who were to collect the proceeds at his death and hold them for the benefit of his wife, children, and grandchildren. Before transferring these policies to the trustees decedent borrowed upon them their maximum loan value. After the transfer the premiums were paid by the decedent or by loans made upon the policies by the trustees or by the application of dividends to premiums. The trustees held no other assets. The transfer by decedent of the…
1Opinion of the Court
OPINION.
Kern, Judge:
In 1932 decedent was the owner of certain policies insuring his life and calling for the payment at his death of $923,868.60. These policies were taken out by decedent prior to 1918. The record does not disclose whether the proceeds of the policies were payable upon his death to named beneficiaries or to his estate. In 1932, and “motivated solely by [his] desire to avoid estate taxes” which might be payable upon these life insurance policies, he transferred them by irrevocable assignment to trustees, the beneficiaries being his wife, his children, and his grandchildren.…
2Cases cited6 opinions
- Helvering v. HallockSupreme Court of the United States · 1940
- Chase National Bank v. United StatesSupreme Court of the United States · 1929
- United States v. JacobsSupreme Court of the United States · 1939
- Lewellyn v. FrickSupreme Court of the United States · 1925
- Bingham v. United StatesSupreme Court of the United States · 1935
1 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Sullivan v. CommissionerUnited States Tax Court · 1948
- Hull v. CommissionerUnited States Tax Court · 1962
- McIntosh v. CommissionerUnited States Tax Court · 1956
- Estate of Garrett v. CommissionerUnited States Tax Court · 1947
- Estate of Showers v. CommissionerUnited States Tax Court · 1950
28 more not listed; retrieve them via the Exa API.