Legal Opinion

Lacey v. Commissioner

United States Tax Court

Decided December 3, 1963No. Docket No. 88383Published

Petitioners, during the years in issue, together owned 50 percent of the stock of the Russell-Lacey Manufacturing Co., Inc. Edward D. Lacey, as a step toward having the corporation obtain "key man" or "business insurance" on his life, took out two $ 50,000 life insurance policies on his life with his estate being designated as beneficiary on the first policy and the company on the second. The beneficiary on the latter policy was changed to Lacey's estate.

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Petitioners, during the years in issue, together owned 50 percent of the stock of the Russell-Lacey Manufacturing Co., Inc. Edward D. Lacey, as a step toward having the corporation obtain "key man" or "business insurance" on his life, took out two $ 50,000 life insurance policies on his life with his estate being designated as beneficiary on the first policy and the company on the second. The beneficiary on the latter policy was changed to Lacey's estate. Lacey then proceeded to assign these policies to the corporation, but instead of making an absolute assignment, only collaterally assigned…

1Opinion of the Court

Edward D. Lacey and Lois C. Lacey, Petitioners, v. Commissioner of Internal Revenue, Respondent

Lacey v. Commissioner

Docket No. 88383

United States Tax Court

41 T.C. 329; 1963 U.S. Tax Ct. LEXIS 8;

December 3, 1963, Filed

Decision will be entered under Rule 50.

Petitioners, during the years in issue, together owned 50 percent of the stock of the Russell-Lacey Manufacturing Co., Inc. Edward D. Lacey, as a step toward having the corporation obtain "key man" or "business insurance" on his life, took out two $ 50,000 life insurance policies on his life with his estate being designated as beneficiary on…

Also in this document: Dissent.

2Cases cited20 opinions

  1. Paramount-Richards Theatres, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
  2. Massaglia v. CommissionerUnited States Tax Court · 1959
  3. Jones v. GloverSupreme Court of Georgia · 1893
  4. Adams v. CommissionerUnited States Board of Tax Appeals · 1929
  5. Blount v. Metropolitan Life Insurance Co.Supreme Court of Georgia · 1941

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