Johnson v. Commissioner
United States Tax Court
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.
Read the full summary
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
- Byers v. Commissioner of Internal Revenue. Byers Transp. Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952
- Epstein v. CommissionerUnited States Tax Court · 1969
- Clark v. CommissionerUnited States Board of Tax Appeals · 1935
- Genshaft v. CommissionerUnited States Tax Court · 1975
- Johnson v. CommissionerUnited States Tax Court · 1980