Jones v. Commissioner
United States Tax Court
Petitioner purchased from a dealer in remainder interests in trust estates, two contingent remainders, and the dealer assigned to him insurance policies covering the lives of the remaindermen whose interests petitioner purchased. After the death of the life tenants petitioner canceled the insurance policies and transferred the interests in the trusts to another for the purpose of achieving capital gains treatment of the profits.
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Petitioner purchased from a dealer in remainder interests in trust estates, two contingent remainders, and the dealer assigned to him insurance policies covering the lives of the remaindermen whose interests petitioner purchased. After the death of the life tenants petitioner canceled the insurance policies and transferred the interests in the trusts to another for the purpose of achieving capital gains treatment of the profits. Held: (1) The gain received by petitioner from the sale of the remainder interests constitutes ordinary income. (2) The net costs to petitioner of the insurance…
1Opinion of the Court
Donald B. Jones and Beverley V. Jones, Petitioners, v. Commissioner of Internal Revenue, Respondent
Jones v. Commissioner
Docket No. 94347
United States Tax Court
40 T.C. 249; 1963 U.S. Tax Ct. LEXIS 131;
May 9, 1963, Filed
Decision will be entered under Rule 50.
Petitioner purchased from a dealer in remainder interests in trust estates, two contingent remainders, and the dealer assigned to him insurance policies covering the lives of the remaindermen whose interests petitioner purchased. After the death of the life tenants petitioner canceled the insurance policies and transferred the interests in…
2Cases cited34 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Osenbach v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1952
- Commissioner of Internal Revenue v. J. I. Morgan and Frances MorganCourt of Appeals for the Ninth Circuit · 1959
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