Legal Opinion

Loeb v. Commissioner

United States Tax Court

Decided October 11, 1957No. Docket No. 60154Published

Sec. 811 (g) (2) (A), I. R. C. 1939. Held: 1. On the facts, insurance proceeds received by decedent's wife properly includible in the gross estate of decedent because decedent indirectly paid all premiums thereon. 2. This section is not unconstitutional as a direct unapportioned tax on property or as being an arbitrary and capricious taking of property without due process of law.

1Opinion of the Court

Estate of Clarence H. Loeb, Deceased, Bessie Robinson Loeb, Isidore Robinson and Harry Robinson, Executors, Petitioners, v. Commissioner of Internal Revenue, Respondent

Loeb v. Commissioner

Docket No. 60154

United States Tax Court

29 T.C. 22; 1957 U.S. Tax Ct. LEXIS 67;

October 11, 1957, Filed

Decision will be entered for the respondent.

Sec. 811 (g) (2) (A), I. R. C. 1939. Held: 1. On the facts, insurance proceeds received by decedent's wife properly includible in the gross estate of decedent because decedent indirectly paid all premiums thereon. 2. This section is not unconstitutional as a direct…

2Cases cited23 opinions

  1. Helvering v. HallockSupreme Court of the United States · 1940
  2. Knowlton v. MooreSupreme Court of the United States · 1900
  3. Chase National Bank v. United StatesSupreme Court of the United States · 1929
  4. Tyler v. United StatesSupreme Court of the United States · 1930
  5. Heiner v. DonnanSupreme Court of the United States · 1932

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