Legal Opinion

Johnson v. Commissioner

United States Tax Court

Decided September 17, 1980No. Docket No. 2393-78Published

Petitioners owned 31 percent of Clinton State Bank (CSB). In 1970, petitioner-wife established a life insurance trust funded with policies covering the life of petitioner-husband. The trust was intended for the benefit of petitioner-wife, petitioners' son and daughter-in-law, and petitioners' grandchildren. In 1973 and 1974, CSB decided to purchase two "split-dollar" life insurance policies on petitioner-husband's life.

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Petitioners owned 31 percent of Clinton State Bank (CSB). In 1970, petitioner-wife established a life insurance trust funded with policies covering the life of petitioner-husband. The trust was intended for the benefit of petitioner-wife, petitioners' son and daughter-in-law, and petitioners' grandchildren. In 1973 and 1974, CSB decided to purchase two "split-dollar" life insurance policies on petitioner-husband's life. Thereafter, CSB paid the entire premiums on each policy. Upon the death of petitioner-husband, CSB was entitled to the cash surrender value of each policy and the trust…

1Opinion of the Court

Howard Johnson and Nobia F. Johnson, Petitioners v. Commissioner of Internal Revenue, Respondent

Johnson v. Commissioner

Docket No. 2393-78

United States Tax Court

74 T.C. 1316; 1980 U.S. Tax Ct. LEXIS 61;

September 17, 1980, Filed

Decision will be entered for the respondent.

Petitioners owned 31 percent of Clinton State Bank (CSB). In 1970, petitioner-wife established a life insurance trust funded with policies covering the life of petitioner-husband. The trust was intended for the benefit of petitioner-wife, petitioners' son and daughter-in-law, and petitioners' grandchildren. In 1973 and 1974,…

2Cases cited5 opinions

  1. Byers v. Commissioner of Internal Revenue. Byers Transp. Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952
  2. Epstein v. CommissionerUnited States Tax Court · 1969
  3. Clark v. CommissionerUnited States Board of Tax Appeals · 1935
  4. Genshaft v. CommissionerUnited States Tax Court · 1975
  5. Johnson v. CommissionerUnited States Tax Court · 1980

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