In Re Tax Appeal of the Von Hamm-Young Co.

OPINION OF THE COURT BY

PETERS, J.

This appeal presents for review the single question of whether a corporation may deduct .from gross income the annual cost of current life insurance effected by it in its favor upon the life of its president and general manager under the income tax law as it existed during the taxable years 1932 to 1936, both inclusive.

The von Hamm-Young Company, Limited, an Hawaiian corporation, effected insurance upon the life of its president and general manager, C. C. von Hamm, with itself as beneficiary. There are two policies of $100,000 each. It was agreed between the…