Legal Opinion
S. M. Friedman and Esther G. Friedman v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided June 12, 1965No. 15979PublishedCited by 19 opinions
1Opinion of the Court
WEICK, Chief Judge.
S. M. Friedman was the owner of a twenty-year endowment policy in the face amount of $100,000, issued to him by Mutual Benefit Life Insurance Company on October 28, 1938. 1 His adjusted basis therefor at the times pertinent here was $60,000.
In 1957 and 1958 Friedman arranged with the Insurance Company to divide this large policy into five separate smaller policies totaling $100,000 and containing substantially the same provisions as the original single policy, except for the maturity values. Friedman then sold three of the policies to different charitable organizations for…
2Cases cited13 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Harrison v. SchaffnerSupreme Court of the United States · 1941
- Helvering v. EubankSupreme Court of the United States · 1941
8 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Kinsey v. CommissionerUnited States Tax Court · 1972
- S. C. Johnson & Son, Inc. v. CommissionerUnited States Tax Court · 1975
- Jacobs v. United StatesDistrict Court, S.D. Ohio · 1966
- John L. Greer, Sr., and Wife, Russell Z. Greer v. United StatesCourt of Appeals for the Sixth Circuit · 1969
- Morgan Guaranty Trust Co. of New York v. United StatesUnited States Court of Claims · 1978
14 more not listed; retrieve them via the Exa API.