Legal Opinion
Gerard Piel and Eleanor Jackson Piel v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided January 25, 1965No. 28852_1PublishedCited by 29 opinions
1Opinion of the Court
MOORE, Circuit Judge.
Petitioners, Gerard Piel and Eleanor Jackson Piel, seek to review a decision of the Tax Court upholding a deficiency in their income tax for 1957. This case again presents the troublesome question whether a taxpayer may take as a tax deduction from yearly income under the alimony provisions of the Internal Revenue Code of 1954 premiums paid toward life insurance on his own life for the benefit of his former wife. The facts are not seriously in dispute and may be summarized as follows.
In 1955 Gerard Piel was divorced from his then wife, Mary, in Nevada. A previously…
2Cases cited14 opinions
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Merchants' Loan & Trust Co. v. SmietankaSupreme Court of the United States · 1921
- Daine v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1948
- Smith's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- Carmichael v. CommissionerUnited States Tax Court · 1950
9 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Fono v. CommissionerUnited States Tax Court · 1982
- Ward v. CommissionerUnited States Tax Court · 1986
- Emerson Institute v. United StatesCourt of Appeals for the D.C. Circuit · 1966
- Taylor v. CommissionerUnited States Tax Court · 1965
- Richard E. And Helen v. Stevens v. Commissioner of Internal Revenue, Wanda Z. Stevens v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1971
24 more not listed; retrieve them via the Exa API.