Webber v. Commissioner
United States Tax Court
P, a U.S. citizen, established a grantor trust that purchased "private placement" variable life insurance policies insuring the lives of two elderly relatives. P and various family members were the beneficiaries of these policies. The premiums paid for the policies, less various expenses, were placed in separate accounts whose assets inured exclusively to the benefit of the policies.
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P, a U.S. citizen, established a grantor trust that purchased "private placement" variable life insurance policies insuring the lives of two elderly relatives. P and various family members were the beneficiaries of these policies. The premiums paid for the policies, less various expenses, were placed in separate accounts whose assets inured exclusively to the benefit of the policies. The money in the separate accounts was used to purchase investments in startup companies with which P was intimately familiar and in which he otherwise invested personally and through private-equity funds he…
1Opinion of the Court
Lauber, Judge:
Petitioner is a venture-capital investor and private-equity fund manager. He established a grantor trust that purchased “private placement” variable life insurance policies insuring the lives of two elderly relatives. These policies were purchased from Lighthouse Capital Insurance Co. (Lighthouse), a Cayman Islands company. Petitioner and various family members were the beneficiaries of these policies.
The premium paid for each policy; after deduction of a mortality risk premium and an administrative charge, was placed in a separate account underlying the policy. The assets in…
2Cases cited43 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Welch v. HelveringSupreme Court of the United States · 1933
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Gregory v. HelveringSupreme Court of the United States · 1935
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