Legal Opinion

Dobrzensky v. Commissioner

United States Board of Tax Appeals

Decided April 10, 1936No. Docket No. 77017Published

1. ESTATE TAX - LIFE INSURANCE - REVENUE ACT OF 1926, SECTION 302(g). - The life of the decedent was insured on his application. The policy premiums were paid by the then corporate beneficiary, of which he was managing director. Later the policy was assigned to decedent "as some slight evidence of appreciation and recognition of these valuable services." Decedent then designated his wife as beneficiary, but, until his death, retained the right to change the beneficiary.

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1. ESTATE TAX - LIFE INSURANCE - REVENUE ACT OF 1926, SECTION 302(g). - The life of the decedent was insured on his application. The policy premiums were paid by the then corporate beneficiary, of which he was managing director. Later the policy was assigned to decedent "as some slight evidence of appreciation and recognition of these valuable services." Decedent then designated his wife as beneficiary, but, until his death, retained the right to change the beneficiary. Held: (a) The payment of the premiums by the corporation was compensation for decedent's services. Frank D. Yuengling,27…

1Opinion of the Court

M. W. DOBRZENSKY, AS EXECUTOR OF THE ESTATE OF WILLIAM GLENN MARVIN, DECREASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Dobrzensky v. Commissioner

Docket No. 77017.

United States Board of Tax Appeals

34 B.T.A. 305; 1936 BTA LEXIS 713;

April 10, 1936, Promulgated

1. ESTATE TAX - LIFE INSURANCE - REVENUE ACT OF 1926, SECTION 302(g). - The life of the decedent was insured on his application. The policy premiums were paid by the then corporate beneficiary, of which he was managing director. Later the policy was assigned to decedent "as some slight evidence of appreciation and…

2Cases cited8 opinions

  1. Adams v. CommissionerUnited States Board of Tax Appeals · 1929
  2. Igleheart v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Ballinger v. CommissionerUnited States Board of Tax Appeals · 1931
  4. Yuengling v. CommissionerUnited States Board of Tax Appeals · 1933
  5. Moore v. CommissionerUnited States Board of Tax Appeals · 1935

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