Atlantic Oil Company v. George D. Patterson, District Director of Internal Revenue

Proceeds of a life insurance policy are not includable in gross income and therefore not taxable. Internal Revenue Code of 1954, § 101(a) (1). The question presented by this appeal is whether the accident insurance policy in suit was void as a wagering contract, and its proceeds therefore taxable. The jury so found. We find no basis in the record for disturbing the jury’s verdict.

The taxpayer’s “company policy” is to have accident insurance on its truck drivers. The life insurance proceeds are to be paid to the employer; certain health benefits are to be paid to the employee. The employer…