Heffelfinger v. Commissioner
United States Board of Tax Appeals
1. Section 219(h), Revenue Acts of 1924 and 1926, and section 167, Revenue Act of 1928, providing for the inclusion in the computation of the net income of the grantor of a trust of any part of the income of the trust which is or may be applied to the payment of premiums upon policies of insurance on the life of the grantor, make no distinction either between endowment policies and other kinds of policies, or between that part of a particular premium which equals the cost of…
Read the full summary
1. Section 219(h), Revenue Acts of 1924 and 1926, and section 167, Revenue Act of 1928, providing for the inclusion in the computation of the net income of the grantor of a trust of any part of the income of the trust which is or may be applied to the payment of premiums upon policies of insurance on the life of the grantor, make no distinction either between endowment policies and other kinds of policies, or between that part of a particular premium which equals the cost of protection and the excess paid over that amount, which excess may represent an investment. 2. Where the grantor of two…
1Opinion of the Court
FRANK T. HEFFELFINGER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Heffelfinger v. Commissioner
Docket Nos. 41145, 44852, 53881, 63407, 69694, 73479.
United States Board of Tax Appeals
32 B.T.A. 1232; 1935 BTA LEXIS 833;
August 20, 1935, Promulgated
1. Section 219(h), Revenue Acts of 1924 and 1926, and section 167, Revenue Act of 1928, providing for the inclusion in the computation of the net income of the grantor of a trust of any part of the income of the trust which is or may be applied to the payment of premiums upon policies of insurance on the life of the grantor, make no…
2Cases cited1 opinion
- Heffelfinger v. CommissionerUnited States Board of Tax Appeals · 1935