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.
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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
Irwin, Judge:
By letter dated December 13, 1977, respondent determined deficiencies in petitioners’ 1974 and 1975 income taxes of $1,237 and $3,005, respectively. The only issue for our decision is whether payments of premiums on certain policies insuring the life of petitioner, Howard Johnson, by a corporation in which petitioners are shareholders, constitute income to petitioners.
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Petitioners Howard and Nobia F.…
2Cases cited4 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
3Cited by6 opinions
- Cadwell v. CommissionerUnited States Tax Court · 2011
- Brock v. CommissionerUnited States Tax Court · 1982
- Denali Dental Services v. CommissionerUnited States Tax Court · 1989
- Goos v. CommissionerUnited States Tax Court · 1991
- Johnson v. CommissionerUnited States Tax Court · 1980
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