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
John D. Carbine and Eleanor W. Carbine, Petitioners v. Commissioner of Internal Revenue, Respondent
Carbine v. Commissioner
Docket No. 26092-81
United States Tax Court
83 T.C. 356; 1984 U.S. Tax Ct. LEXIS 31; 83 T.C. No. 23;
September 18, 1984. September 18, 1984, Filed
Decision will be entered under Rule 155.
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…
2Cases cited23 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
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