John D. Carbine and Eleanor W. Carbine v. Commissioner of Internal Revenue

ANDERSON, Circuit Judge:

Appellants John D. and Eleanor W. Carbine (“Carbine”) challenge the decision of the Tax Court, 83 T.C. 356, in favor of the Commissioner of Internal Revenue (“Commissioner”) finding them liable for tax deficiencies for the years 1977 and 1978. The issue before us is whether Carbine may deduct premiums paid with respect to an insurance policy on the life of John Carbine. We affirm the decision of the Tax Court that such payments are not deductible.

I. FACTS

Carbine held a twenty percent stock interest in Burgess-Carbine Associates, Inc. (“BCA”), a corporation engaged in…