Estate of Snider v. Commissioner
United States Tax Court
Insured's election before maturity under insurance company's annuity policy to leave principal sum on deposit and receive monthly installments of principal augmented by interest and dividends, held, not to result in constructive receipt of difference between premiums previously paid and cash surrender value, insurance company not being required to pay principal in taxable year.
1Opinion of the Court
OPINION.
OppeR, Judge:
In 1932 decedent secured a life annuity contract under the terms of which he could, upon the maturity of the contract in 1953, receive monthly specified payments for the remainder of his life. The contract entitled him prior to maturity to make certain life or refund annuities’ elections, and in 1950, the instant tax year, and prior to maturity an alternative election was agreed upon between decedent and the insurance company pursuant to which he received tile company’s agreement to pay the principal sum, plus interest and dividends, in specified monthly installments…
2Cases cited11 opinions
- Helvering v. HelmholzSupreme Court of the United States · 1935
- Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- White v. PoorSupreme Court of the United States · 1935
- Thornley v. Commissioners of Internal RevenueCourt of Appeals for the Third Circuit · 1945
- Thornley v. CommissionerUnited States Tax Court · 1943
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Estate of Snider v. CommissionerUnited States Tax Court · 1962
- Estate of Silverman v. CommissionerUnited States Tax Court · 1974
- Estate of Silverman v. CommissionerUnited States Tax Court · 1974
- Estate of Snider v. CommissionerUnited States Tax Court · 1959
- Estate of Snider v. CommissionerUnited States Tax Court · 1962
3 more not listed; retrieve them via the Exa API.