Hall v. Commissioner
United States Tax Court
Deduction -- Nonbusiness Expense -- Premiums Paid on Insurance. -- The petitioner held insurance on the life of a debtor of petitioner's estate to secure payment of the debt principal. The debtor was not obligated to reimburse petitioner for its payments of premiums. Petitioner paid the premiums out of the principal of the trust.
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Deduction -- Nonbusiness Expense -- Premiums Paid on Insurance. -- The petitioner held insurance on the life of a debtor of petitioner's estate to secure payment of the debt principal. The debtor was not obligated to reimburse petitioner for its payments of premiums. Petitioner paid the premiums out of the principal of the trust. Under the facts, held, that (1) the estate was not engaged in a business, and the insurance premium expense is not deductible under section 23 (a) (1) (A); and that (2) the payment of insurance premiums is not a nonbusiness expense under section 23 (a) (2) and is not…
1Opinion of the Court
Estate of Frank Hall, Deceased, Irving Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Hall v. Commissioner
Docket No. 22725
United States Tax Court
17 T.C. 20; 1951 U.S. Tax Ct. LEXIS 126;
July 17, 1951, Promulgated
Decision will be entered for the respondent.
Deduction -- Nonbusiness Expense -- Premiums Paid on Insurance. -- The petitioner held insurance on the life of a debtor of petitioner's estate to secure payment of the debt principal. The debtor was not obligated to reimburse petitioner for its payments of premiums. Petitioner paid the premiums out of the…
Also in this document: Dissent.
2Cases cited13 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- United States v. PyneSupreme Court of the United States · 1941
- Leslie v. CommissionerUnited States Tax Court · 1946
- City Bank Farmers Trust Co. v. HelveringSupreme Court of the United States · 1941
8 more not listed; retrieve them via the Exa API.