Legal Opinion

Cohen v. Commissioner

United States Tax Court

Decided March 27, 1963No. Docket No. 89118Published

Petitioner, in form, assigned three life insurance policies upon his life to a third party who, in accordance with an agreement between them, surrendered the policies, received the cash surrender value plus accumulated dividends and interest thereon left on deposit, and paid the same to petitioner who thereupon paid the third party for his services.

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Petitioner, in form, assigned three life insurance policies upon his life to a third party who, in accordance with an agreement between them, surrendered the policies, received the cash surrender value plus accumulated dividends and interest thereon left on deposit, and paid the same to petitioner who thereupon paid the third party for his services. Held, the transaction between petitioner and the third party did not constitute a bona fide sale of the insurance policies but did constitute his personal surrender thereof through the third party as his agent. Held, further, periodic increments…

1Opinion of the Court

Theodore H. Cohen and Olive B. Cohen, Petitioners, v. Commissioner of Internal Revenue, Respondent

Cohen v. Commissioner

Docket No. 89118

United States Tax Court

39 T.C. 1055; 1963 U.S. Tax Ct. LEXIS 166;

March 27, 1963, Filed

Decision will be entered under Rule 50.

Petitioner, in form, assigned three life insurance policies upon his life to a third party who, in accordance with an agreement between them, surrendered the policies, received the cash surrender value plus accumulated dividends and interest thereon left on deposit, and paid the same to petitioner who thereupon paid the third party for…

2Cases cited9 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
  3. Griffith v. CommissionerUnited States Tax Court · 1961
  4. Cohen v. CommissionerUnited States Tax Court · 1963
  5. Jones v. CommissionerUnited States Tax Court · 1962

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