Legal Opinion
Swanson v. Commissioner
Court of Appeals for the Eighth Circuit
Decided June 13, 1975No. Nos. 74-1594, 74-1777, 74-1595, 74-1778, 74-1596 and 74-1779PublishedCited by 9 opinions
1Opinion of the Court
STEPHENSON, Circuit Judge.
These appeals and cross-appeals from a decision of the Tax Court, reported at P-H Memo T.C. 1 74,061 (1974), present the question of whether proceeds received under life insurance policies are excludable from gross income in the case of a transfer for valuable consideration under the exceptions created in Section 101(a)(2)(B) (26 U.S.C. § 101(a)(2)(B)).1
The government appeals from that portion of the Tax Court decision holding that life insurance proceeds payable upon the death of the grantor to grantor trusts are excludable because the grant- or was considered to be…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Parker v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1948
- Henry W. Sohosky v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1973
- Herberts v. CommissionerUnited States Tax Court · 1948
3Cited by9 opinions
- Ringwalt v. United StatesCourt of Appeals for the Eighth Circuit · 1977
- American Nurseryman Publishing Co. v. CommissionerUnited States Tax Court · 1980
- Madorin v. CommissionerUnited States Tax Court · 1985
- W. Clarke Swanson, Jr., 1950 Trust Under Instrument Dated January 3, 1955, Swanco Trust Company, Trustee, and Cross-Appellant v. Commissioner of Internal Revenue, and Cross-Appellee. Carol Swanson Rhoden, 1950 Trust Under Instrument Dated January 3, 1955, Swanco Trust Company, Trustee, and Cross-Appellant v. Commissioner of Internal Revenue, and Cross-Appellee. Gerock Hurley Swanson, 1950 Trust Under Instrument Dated January 3, 1955, Swanco Trust Company, Trustee, and Cross-Appellant v. Commissioner of Internal Revenue, and Cross-AppelleeCourt of Appeals for the Eighth Circuit · 1975
- American Nurseryman Publishing Co. v. CommissionerUnited States Tax Court · 1980
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