Legal Opinion

Keystone Consol. Publishing Co. v. Commissioner

United States Board of Tax Appeals

Decided October 18, 1932No. Docket No. 46311PublishedCited by 4 opinions

Where a corporation took out insurance policies in 1916 and 1921 upon the lives of its officers who were also stockholders, made itself the beneficiary of the policies, and paid the premiums thereon until 1926, when it sold the policies to the insured at a price equal to the cash surrender value thereof, held, no loss was sustained by the corporation upon the sale of the policies. Standard Brewing Co.,6 B.T.A. 980, followed.

1Opinion of the Court

OPINION.

Goodeich :

Petitioner contests a deficiency in income taxes for the calendar year 1926 of $944.05. The sole issue involved is whether the excess of premiums paid on life insurance policies carried by a corporation on its officers (who were also stockholders) over the amount received from sale of the policies in 1926 is deductible from income as a loss sustained by the corporation.

Petitioner is a corporation, having its principal office at Tenth Avenue and 36th Street, New York City.

The parties, by counsel, have stipulated the facts as follows:

The petitioner took out insurance policies…

2Cases cited1 opinion

  1. Lucas v. AlexanderSupreme Court of the United States · 1929

3Cited by4 opinions

  1. London Shoe Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
  2. Keystone Consol. Publishing Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  3. London Shoe Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
  4. London Shoe Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API