Lacey v. Commissioner
United States Tax Court
Petitioners, during the years in issue, together owned 50 percent of the stock of the Russell-Lacey Manufacturing Co., Inc. Edward D. Lacey, as a step toward having the corporation obtain "key man" or "business insurance" on his life, took out two $ 50,000 life insurance policies on his life with his estate being designated as beneficiary on the first policy and the company on the second. The beneficiary on the latter policy was changed to Lacey's estate.
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Petitioners, during the years in issue, together owned 50 percent of the stock of the Russell-Lacey Manufacturing Co., Inc. Edward D. Lacey, as a step toward having the corporation obtain "key man" or "business insurance" on his life, took out two $ 50,000 life insurance policies on his life with his estate being designated as beneficiary on the first policy and the company on the second. The beneficiary on the latter policy was changed to Lacey's estate. Lacey then proceeded to assign these policies to the corporation, but instead of making an absolute assignment, only collaterally assigned…
1Opinion of the Court
OPINION
For each of the years 1951 through 1955, the respondent increased reported income of the petitioner by the amounts which were paid as premiums on the life of the petitioner by the company. The respondent included these payments in the petitioners’ income under section 22 (a), 1939 Code, and section 61 of the 1954 Code, relying on such cases as George Matthew Adams, 18 B.T.A. 381 (1929); N. Loring Danforth, 18 B.T.A. 1221 (1930); Frank D. Yuengling, 27 B.T.A. 782 (1933), affd. 69 F. 2d 971 (C.A. 3, 1934), and Commissioner v. Bonwit, 87 F. 2d 784 (C.A. 2, 1937), reversing 33 B.T.A. 507,…
2Cases cited18 opinions
- Jones v. GloverSupreme Court of Georgia · 1893
- Adams v. CommissionerUnited States Board of Tax Appeals · 1929
- Blount v. Metropolitan Life Insurance Co.Supreme Court of Georgia · 1941
- Whittle v. NottinghamSupreme Court of Georgia · 1927
- Danforth v. CommissionerUnited States Board of Tax Appeals · 1930
13 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Lord v. CommissionerUnited States Tax Court · 1973
- Estate of Grant H. Piggott, Deceased, David S. Piggott and Albert F. Piggott, Co-Administrators v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965
- Centre v. CommissionerUnited States Tax Court · 1970
- Drake University v. CommissionerUnited States Tax Court · 1965
- Centre v. CommissionerUnited States Tax Court · 1970
4 more not listed; retrieve them via the Exa API.