Legal Opinion

Barrett v. Commissioner

United States Tax Court

Decided August 31, 1964No. Docket No. 4692-62Published

Petitioner surrendered or exchanged 12 endowment policies on their maturity dates for 12 paid-up life insurance policies.

Read the full summary

Petitioner surrendered or exchanged 12 endowment policies on their maturity dates for 12 paid-up life insurance policies. Held: 1. Petitioners realized ordinary income in the amount of the excess of the cost of the paid-up life insurance policies over the cost of the endowment policies surrendered. 2. No estoppel exists against respondent because of statements made in a letter sent to one of petitioners from the office of respondent in response to a letter requesting a ruling.

1Opinion of the Court

W. Stanley Barrett and Irene B. Barrett, Petitioners, v. Commissioner of Internal Revenue, Respondent

Barrett v. Commissioner

Docket No. 4692-62

United States Tax Court

42 T.C. 993; 1964 U.S. Tax Ct. LEXIS 49;

August 31, 1964, Filed

Decision will be entered for respondent.

Petitioner surrendered or exchanged 12 endowment policies on their maturity dates for 12 paid-up life insurance policies. Held:

1. Petitioners realized ordinary income in the amount of the excess of the cost of the paid-up life insurance policies over the cost of the endowment policies surrendered.

2. No estoppel exists against…

2Cases cited11 opinions

  1. Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
  2. Commissioner of Internal Revenue v. Percy W. Phillips and Betty R. Phillips (Husband and Wife)Court of Appeals for the Fourth Circuit · 1960
  3. Harry Rosen and Rose Rosen v. United StatesCourt of Appeals for the Third Circuit · 1961
  4. Arnfeld v. United StatesUnited States Court of Claims · 1958
  5. Jones v. CommissionerUnited States Tax Court · 1962

6 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API