Keefe v. Commissioner
United States Tax Court
1. Petitioner and his business partner each took out and maintained life insurance in equal amounts on his own life, and each named the other his beneficiary without reserving a power to change the beneficiary.
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1. Petitioner and his business partner each took out and maintained life insurance in equal amounts on his own life, and each named the other his beneficiary without reserving a power to change the beneficiary. They agreed that, in the event of the death of either, the insurance proceeds collected by the survivor were to be turned over to the decedent's representative, and such payment, together with a portion of certain cash, was to be in satisfaction of the decedent's interest in the partnership. In addition to becoming the sole owner of the business, the surviving partner was to reacquire…
1Opinion of the Court
OPINION.
Raum, Judge:
The petitioner seeks to deduct from his gross income amounts which he paid as premiums on insurance on his own life. However, if petitioner “is directly or indirectly a beneficiary under such [policies]” within the meaning of section 24 (a) (4) of the Internal Revenue Code,1 the claimed deduction is forbidden, and it becomes unnecessary to consider other objections to its allowance alternatively asserted by the respondent.
The petitioner and his business partner each took out insurance on his own life; each named the other as the beneficiary under the policies he obtained,…
2Cases cited2 opinions
- Yarnall v. CommissionerUnited States Tax Court · 1947
- Birch Ranch & Oil Co. v. CommissionerUnited States Tax Court · 1949
3Cited by34 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Judge v. CommissionerUnited States Tax Court · 1987
- Logan v. CommissionerUnited States Tax Court · 1986
- Estate of Parshelsky v. CommissionerCourt of Appeals for the Second Circuit · 1962
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