Castner Garage, Ltd. v. Commissioner
United States Board of Tax Appeals
GROSS INCOME - EXEMPTION - COMPENSATION FOR INJURY OR SICKNESS. - The exemption allowed in sections 22(b)(5) of the Revenue Acts of 1934 and 1936, of amounts received through accident or health insurance as compensation for personal injuries or sickness, is not limited to the insured or to individual taxpayers other than the insured, but includes corporations which have insurable interests.
1Opinion of the Court
OPINION.
Murdock:
The Commissioner determined deficiencies as follows:
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The issue for decision by the Board is whether and to what extent the petitioners are taxable upon amounts received by them in 1935 and 1936 from the Prudential Insurance Co. of America as disability payments under policies of combined life, health, and accident insurance upon their president, Charles C. Pittam. .The Board adopts as its findings of fact the stipulations of the parties, together with exhibits attached thereto.
*2The Castner Garage, Ltd., and Universal Motor Co., Ltd., hereinafter referred to as…
2Cases cited2 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- United States v. Supplee-Biddle Hardware Co.Supreme Court of the United States · 1924
3Cited by6 opinions
- P & X Mkts. v. CommissionerUnited States Tax Court · 1996
- Rugby Prods. v. CommissionerUnited States Tax Court · 1993
- Castner Garage, Ltd. v. CommissionerUnited States Board of Tax Appeals · 1940
- P & X Markets, Inc. v. CommissionerUnited States Tax Court · 1996
- P & X Mkts. v. CommissionerUnited States Tax Court · 1996
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