Regenstein v. Commissioner
United States Tax Court
Petitioner and others worked in developing a plan for group life insurance for Federal Government employees, the basic ideas of which were included in the Federal Employees' Group Life Insurance Act of 1954 as passed by Congress.
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Petitioner and others worked in developing a plan for group life insurance for Federal Government employees, the basic ideas of which were included in the Federal Employees' Group Life Insurance Act of 1954 as passed by Congress. Held, amount paid to petitioner by the Metropolitan Life Insurance Company on behalf of itself and its associated companies for which he sold, assigned, and transferred to these companies all right, title, and interest in and to said plan of and ideas for group life insurance for Federal Government employees and released all claims against these companies arising out…
1Opinion of the Court
Scott, Judge:
The respondent determined a deficiency in petitioners’ income tax for the taxable year 1954 in the amount of $3,740.61. The only issue for decision is whether the amount of $10,000 received by Harold L. Regenstein in 1954 from the Metropolitan Life Insurance Company is taxable as ordinary income rather than as long-term capital gain.
FINDINGS OF FACT.
The petitioners are husband and wife whose income tax return for the year 1954 was filed with the district director of internal revenue for the Upper Manhattan District of New York.
Harold L. Regenstein, hereinafter referred to as the…
2Cases cited9 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Kaltreider v. CommissionerUnited States Tax Court · 1957
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3Cited by13 opinions
- Luna v. CommissionerUnited States Tax Court · 1964
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- Michot v. CommissionerUnited States Tax Court · 1982
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