Igleheart v. Commissioner
United States Tax Court
Prior to the taxable year 1941, petitioner executed nine agreements with three insurance companies. In consideration of a single "premium" payment by petitioner, the companies agreed to make annual payments based upon a presumed rate of interest. The principal sum was to be returned to petitioner on surrender of the contract or paid to his nominees at his death. Held, the annual payments did not include any return of invested capital.
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Prior to the taxable year 1941, petitioner executed nine agreements with three insurance companies. In consideration of a single "premium" payment by petitioner, the companies agreed to make annual payments based upon a presumed rate of interest. The principal sum was to be returned to petitioner on surrender of the contract or paid to his nominees at his death. Held, the annual payments did not include any return of invested capital. These amounts were not received as annuities under an annuity contract and, therefore, are not subject to taxation under the formula prescribed in section 22…
1Opinion of the Court
OPINION.
Leech, Judge-.
This proceeding involves a deficiency in income tax for the calendar year 1941 in the amount of $2,232.49. The respondent asks for an increased deficiency based on additional taxable income in the amount of $92.63. The sole issue is the extent to which amounts received under nine contracts with various life insurance companies in the taxable year are includible in petitioner’s gross income. All the facts were stipulated and are incorporated in our findings of fact by reference. The material facts may be summarized as follows:
Petitioner is an individual who resides in…
2Cases cited1 opinion
- Thornley v. CommissionerUnited States Tax Court · 1943
3Cited by11 opinions
- Edgar v. CommissionerUnited States Tax Court · 1971
- Lazarus v. CommissionerUnited States Tax Court · 1972
- Hunt Foods, Inc. v. CommissionerUnited States Tax Court · 1951
- Zimmermann v. CommissionerUnited States Tax Court · 1955
- Fisher v. CommissionerUnited States Tax Court · 1949
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