Dobrzensky v. Commissioner
United States Board of Tax Appeals
1. ESTATE TAX - LIFE INSURANCE - REVENUE ACT OF 1926, SECTION 302(g). - The life of the decedent was insured on his application. The policy premiums were paid by the then corporate beneficiary, of which he was managing director. Later the policy was assigned to decedent "as some slight evidence of appreciation and recognition of these valuable services." Decedent then designated his wife as beneficiary, but, until his death, retained the right to change the beneficiary.
Read the full summary
1. ESTATE TAX - LIFE INSURANCE - REVENUE ACT OF 1926, SECTION 302(g). - The life of the decedent was insured on his application. The policy premiums were paid by the then corporate beneficiary, of which he was managing director. Later the policy was assigned to decedent "as some slight evidence of appreciation and recognition of these valuable services." Decedent then designated his wife as beneficiary, but, until his death, retained the right to change the beneficiary. Held: (a) The payment of the premiums by the corporation was compensation for decedent's services. Frank D. Yuengling,27…
1Opinion of the Court
OPINION.
Leech :
This proceeding attacks the determination of an estate tax deficiency of $1,003.78 against the estate of William Glenn Marvin, who died January 5,1932, a resident of California.
In making his determination of the deficiency the respondent included in the gross estate of the decedent the proceeds of six policies of life insurance in the amount of $90,763.72, which the representative of the estate did not return for taxation.
We find the facts as stipulated. Only those essential to an understanding of the issues will be repeated here.
The decedent was for many years the attorney and…
2Cases cited1 opinion
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
3Cited by8 opinions
- Commercial Nat. Bank & Trust Co. of NY v. JohnsonDistrict Court, S.D. New York · 1954
- Estate of Shields v. CommissionerUnited States Tax Court · 1943
- Dobrzensky v. CommissionerUnited States Board of Tax Appeals · 1936
- Legallet v. CommissionerUnited States Board of Tax Appeals · 1940
- People v. LacySupreme Court of Colorado · 1965
3 more not listed; retrieve them via the Exa API.