Golsen v. Commissioner
United States Tax Court
T purchased 20 "executive special" life insurance policies that were specially designed, calling for abnormally high premiums and providing for correspondingly high loan and cash surrender values.
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T purchased 20 "executive special" life insurance policies that were specially designed, calling for abnormally high premiums and providing for correspondingly high loan and cash surrender values. As part of a prearranged plan T not only "paid" the first year's premiums but also made "payments" into a "prepaid premium fund" in respect of the premiums to become due in the next 4 years, and he simultaneously "borrowed" back not only the full amount of the "prepaid premium fund" but also the full loan value of the policies created by the first year's premium. His "interest" obligations in…
1Opinion of the Court
Jack E. Golsen and Sylvia H. Golsen, Petitioners v. Commissioner of Internal Revenue, Respondent
Golsen v. Commissioner
Docket No. 5863-65
United States Tax Court
54 T.C. 742; 1970 U.S. Tax Ct. LEXIS 166;
April 9, 1970, Filed
Decision will be entered for the respondent.
T purchased 20 "executive special" life insurance policies that were specially designed, calling for abnormally high premiums and providing for correspondingly high loan and cash surrender values. As part of a prearranged plan T not only "paid" the first year's premiums but also made "payments" into a "prepaid premium fund" in…
Also in this document: Dissent.
2Cases cited35 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
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