Legal Opinion
Estate of Hall v. Commissioner
United States Tax Court
Decided July 17, 1951No. Docket No. 22725PublishedCited by 1 opinion
1Opinion of the Court
OPINION.
IIarron, Judge:
The petitioner contends that the payments of premiums for the insurance on the life of Snedeker are deductible either under section 23 (a) (1) (A) of the Code, as business expense, or under section 23 (a) (2), as nonbusiness expense. The respondent contends that the insurance premium expense is not deductible under either section.
It is held that the executor and trustee of Hall’s estate was not engaged in the conduct of a business on behalf of the beneficiaries of the estate. United States v. Pyne, 313 U. S. 127 (1941); Higgins v. Commissioner (C. A. 2, 1940), 111 F. 2d…
Also in this document: Dissent.
2Cases cited12 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- United States v. PyneSupreme Court of the United States · 1941
- Leslie v. CommissionerUnited States Tax Court · 1946
- City Bank Farmers Trust Co. v. HelveringSupreme Court of the United States · 1941
7 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- United States v. John S. Mellinger and Sweeney J. Doehring, as Executors of the Estate of Mary Edith Giles, DeceasedCourt of Appeals for the Fifth Circuit · 1956