Legal Opinion

Cadwalader v. Commissioner

United States Board of Tax Appeals

Decided January 22, 1929No. Docket No. 13296Published

1. The taxpayer loaned $80,000 to one Stafford. There had been assigned to taxpayer as collateral, life insurance policies on the life of Stafford in the principal amount of $80,000. Stafford became bankrupt and was discharged. At the date of bankruptcy such policies had a cash surrender value of $24,586. The taxpayer did not surrender the policies or otherwise foreclose on them but continued them in force.

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1. The taxpayer loaned $80,000 to one Stafford. There had been assigned to taxpayer as collateral, life insurance policies on the life of Stafford in the principal amount of $80,000. Stafford became bankrupt and was discharged. At the date of bankruptcy such policies had a cash surrender value of $24,586. The taxpayer did not surrender the policies or otherwise foreclose on them but continued them in force. Held, that he continued to hold them as collateral and was not the owner. Held, further, that in the absence of any foreclosure on the collateral, no deduction was allowable under the…

1Opinion of the Court

JOHN CADWALADER, JR., AND T. C. CADWALADER, EXECUTORS, ESTATE OF JOHN CADWALADER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Cadwalader v. Commissioner

Docket No. 13296.

United States Board of Tax Appeals

15 B.T.A. 1; 1929 BTA LEXIS 2938;

January 22, 1929, Promulgated

1. The taxpayer loaned $80,000 to one Stafford. There had been assigned to taxpayer as collateral, life insurance policies on the life of Stafford in the principal amount of $80,000. Stafford became bankrupt and was discharged. At the date of bankruptcy such policies had a cash surrender value of $24,586. The…

2Cases cited1 opinion

  1. Cadwalader v. CommissionerUnited States Board of Tax Appeals · 1929

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