Hall v. Commissioner
United States Tax Court
Life Insurance. -- Under certain life insurance contracts which matured and became payable by reason of death of the insured, petitioner elected to receive, for a period of years and so long thereafter as she lived, periodic payments computed with reference to her life expectancy.
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Life Insurance. -- Under certain life insurance contracts which matured and became payable by reason of death of the insured, petitioner elected to receive, for a period of years and so long thereafter as she lived, periodic payments computed with reference to her life expectancy. As to the portions of such payments which are attributable solely to her being the designated beneficiary of the net proceeds of the policies, the parties have stipulated that they are entirely tax-exempt under section 22 (b) (1), I. R. C. As to the portions of such payments which (although payable under the…
1Opinion of the Court
OPINION.
Tyson, Judge-.
In asserting the deficiency involved, respondent determined that petitioner received as taxable annuities the entire amounts of the periodic payments made under the seven life insurance policies as to which petitioner-beneficiary, after the insured’s death, exercised an option to receive the insurance benefits in such periodic payments. By stipulation and on authority of Katharine C. Pierce, 2 T. C. 832; affd., 146 Fed. (2d) 388; and Law v. Rothensies, 155 Fed. (2d) 13, respondent concedes that the beneficiary’s mere exercise of such option does not bring such periodic…
Also in this document: Concurrence.
2Cases cited2 opinions
- Haverty Realty & Inv. Co. v. CommissionerUnited States Tax Court · 1944
- Pierce v. CommissionerUnited States Tax Court · 1943
3Cited by7 opinions
- Harrison v. CommissionerUnited States Tax Court · 1973
- Allen v. State Tax CommissionMassachusetts Supreme Judicial Court · 1958
- Fisher v. CommissionerUnited States Tax Court · 1949
- Fisher v. CommissionerUnited States Tax Court · 1949
- Fisher v. CommissionerUnited States Tax Court · 1949
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