Estate of Morrissette v. Comm'r
United States Tax Court
In 2006 D's revocable trust, T, entered into two split-dollar life insurance arrangements with three distinct trusts. T then contributed a total of $29.9 million to the trusts in order to fund the purchase of life insurance policies on each of D's three sons.
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In 2006 D's revocable trust, T, entered into two split-dollar life insurance arrangements with three distinct trusts. T then contributed a total of $29.9 million to the trusts in order to fund the purchase of life insurance policies on each of D's three sons. The split-dollar life insurance arrangements provided that T would receive the greater of the cash surrender value of the respective policy or the aggregate premium payments on that policy upon termination of the split-dollar life insurance arrangement or the death of the insured. R determined that the $29.9 million contribution was a…
1Opinion of the Court
ESTATE OF CLARA M. MORRISSETTE, DECEASED, KENNETH MORRISSETTE, DONALD J. MORRISSETTE, AND ARTHUR E. MORRISSETTE, PERSONAL REPRESENTATIVES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Morrissette v. Comm'r
Docket No. 4415-14.
United States Tax Court
146 T.C. 171; 2016 U.S. Tax Ct. LEXIS 12; 146 T.C. No. 11;
April 13, 2016, Filed
An appropriate order will be issued granting petitioners' motion for partial summary judgment.
In 2006 D's revocable trust, T, entered into two split-dollar life insurance arrangements with three distinct trusts. T then contributed a total of $29.9…
2Cases cited11 opinions
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
6 more not listed; retrieve them via the Exa API.
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