Barrett v. Commissioner
United States Tax Court
Petitioner surrendered or exchanged 12 endowment policies on their maturity dates for 12 paid-up life insurance policies.
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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
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Commissioner of Internal Revenue v. Percy W. Phillips and Betty R. Phillips (Husband and Wife)Court of Appeals for the Fourth Circuit · 1960
- Harry Rosen and Rose Rosen v. United StatesCourt of Appeals for the Third Circuit · 1961
- Arnfeld v. United StatesUnited States Court of Claims · 1958
- Jones v. CommissionerUnited States Tax Court · 1962
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