Legal Opinion

Kimberly R. Hale v. Commissioner

United States Tax Court

Decided June 26, 2018No. 18664-14, 10262-15Unpublished

1Opinion of the Court

T.C. Memo. 2018-93

UNITED STATES TAX COURT KIMBERLY R. HALE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 18664-14, 10262-15.1 Filed June 26, 2018. P and H filed joint Federal income tax returns for the years 2004 through 2009. Although each return reported a liability owed, that liability was not paid with the filing of the return. P did not become aware of the unpaid liabilities until after H's death. During his life, H, who was the family's sole income earner, funded life insurance policies that provided P with almost $8 million of benefits upon his death. The…

2Cases cited5 opinions

  1. National Life Insurance v. United StatesSupreme Court of the United States · 1928
  2. United States v. RyersonSupreme Court of the United States · 1941
  3. Pullins v. CommissionerUnited States Tax Court · 2011
  4. Boyle v. Comm'rUnited States Tax Court · 2016
  5. Ogden v. HooksCourt of Appeals of Tennessee · 1941

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