Tennessee Foundry & Machinery Co. v. Commissioner
United States Tax Court
Proceeds of insurance policy received by petitioner from company by which one of its employees who had embezzled some of its funds was insured were not received "by reason of the death of the insured" but were received as restitution of embezzled funds.
1Opinion of the Court
OPINION
Scott, Judge:
Respondent determined a deficiency in petitioner’s income tax for the taxable year ended March 31,1964, in the amount of $12,787.37.
The only issue for decision is whether the proceeds of a life insurance policy received by petitioner in its taxable year ended March 31,1964, are excludable as amounts received “under a life insurance contract * * * by reason of death of the insured,” within the meaning of section 101(a) (^ULC.!».1
All of the facts of this case have been stipulated and are found accordingly.
Petitioner is a corporation organized under the laws of the State of…
2Cases cited6 opinions
- Healy v. CommissionerSupreme Court of the United States · 1953
- Marian Essenfeld v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- McCamant v. CommissionerUnited States Tax Court · 1959
- Grossman & Sons v. CommissionerUnited States Tax Court · 1967
- McConnell v. HenochsbergCourt of Appeals of Tennessee · 1929
1 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Anderson v. CommissionerUnited States Tax Court · 1971
- Harrison v. CommissionerUnited States Tax Court · 1973
- Tennessee Foundry & MacHine Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1968
- Anderson v. CommissionerUnited States Tax Court · 1971
- Harrison v. CommissionerUnited States Tax Court · 1973
1 more not listed; retrieve them via the Exa API.