Legal Opinion
Cecil H. Shirar and Jessie May Shirar v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided November 6, 1990No. 88-7451PublishedCited by 9 opinions
1Opinion of the Court
LEAVY, Circuit Judge:
Cecil H. Shirar (“Shirar”) purchased a life insurance policy to obtain liquidity in the event of his wife’s death. Part of the coverage was financed with funds loaned by the insurer against the cash value of the policy. Shirar sought to deduct the interest on these loans under 26 U.S.C. § 163(a). 1 The Commissioner of Internal Revenue (“Commissioner”) disallowed the deductions and assessed a deficiency. The Tax Court agreed with the Commissioner and upheld the deficiency. We reverse.
FACTS AND PROCEEDINGS -
In 1978, Shirar and his wife, Jessie May, consulted with their…
2Cases cited8 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- David C. Enrici Marianne Enrici Lawrence H. Easterling Phyllis Easterling v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
- Amor F. Pierce and Ida Mae Pierce v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
3 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Kenneth Allen Barbara Allen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1991
- United States v. Victor Wexler, Honorable John W. Bissell, NominalCourt of Appeals for the Third Circuit · 1994
- Internal Revenue Service v. CM Holdings, Inc. (In Re CM Holdings, Inc.)District Court, D. Delaware · 2000
- American Electric Power, Inc. v. United StatesDistrict Court, S.D. Ohio · 2001
- Internal Revenue Service v. CM Holdings, Inc. (In Re CM Holdings, Inc.)District Court, D. Delaware · 1998
4 more not listed; retrieve them via the Exa API.