Occidental Life Ins. Co. v. Commissioner
United States Tax Court
Petitioner paid over to the estate of a Canadian resident, a former agent of petitioner, renewal commissions becoming due on insurance sold by decedent prior to his death, before it had notice that a United States estate tax was due but unpaid by the Canadian estate. Held, petitioner is not liable for payment of the estate tax due by the Canadian estate out of its own assets to the extent of the payments made to the estate.
1Opinion of the Court
Occidental Life Insurance Company of California, Petitioner v. Commissioner of Internal Revenue, Respondent
Occidental Life Ins. Co. v. Commissioner
Docket No. 2630-66
United States Tax Court
50 T.C. 726; 1968 U.S. Tax Ct. LEXIS 84;
August 12, 1968, Filed
Decision will be entered for the petitioner.
Petitioner paid over to the estate of a Canadian resident, a former agent of petitioner, renewal commissions becoming due on insurance sold by decedent prior to his death, before it had notice that a United States estate tax was due but unpaid by the Canadian estate. Held, petitioner is not liable for…
2Cases cited8 opinions
- Bramwell v. United States Fidelity & Guaranty Co.Supreme Court of the United States · 1925
- King v. United StatesSupreme Court of the United States · 1964
- Leuthesser v. CommissionerUnited States Tax Court · 1952
- Irving Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1937
- Livingston v. BeckerDistrict Court, E.D. Missouri · 1929
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