Legal Opinion

Williams v. Commissioner

United States Tax Court

Decided March 29, 1967No. Docket No. 458-66PublishedCited by 28 opinions

Petitioner reinstated a lapsed insurance policy and paid amounts designated as "interest" on back premiums and on a loan outstanding at the time of lapse. Held, such amounts are not deductible under sec. 163, I.R.C. 1954.

1Opinion of the Court

Tannenwald, Judge:

Respondent determined deficiencies in petitioners’ income tax for the taxable years and in the amounts as follows:

Tear Deficiency

1961 _$360.88

1962 _ 216.44

1963 _ 49. 51

All issues raised by the deficiency notice have been settled except the question whether any portion of the sum paid by petitioner in 1961 in connection with the reinstatement of a certain insurance policy constitutes interest within the meaning of section 163 of the Internal Revenue Code of 1954.1

FINDINGS OF FACT

Some of the facts are stipulated and are found accordingly.

George T. Williams and Marcia J.…

2Cases cited5 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
  3. Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1931
  4. Gilman v. CommissionerUnited States Board of Tax Appeals · 1930
  5. Christensen v. CommissionerUnited States Tax Court · 1963

3Cited by28 opinions

  1. Estate of Franklin v. CommissionerUnited States Tax Court · 1975
  2. Titcher v. CommissionerUnited States Tax Court · 1971
  3. Dunlap v. CommissionerUnited States Tax Court · 1980
  4. Howlett v. CommissionerUnited States Tax Court · 1971
  5. Midkiff v. CommissionerUnited States Tax Court · 1991

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