Jones v. Commissioner
United States Tax Court
Petitioner owned an endowment insurance policy on his life in the amount of $ 10,000. Thirty-five days before the policy matured and when its cash value was $ 9,971.20, petitioner assigned it to a bank for $ 9,953.60. Held, the assignment was bona fide but the entire gain realized ($ 2,263.70) is taxable as ordinary income. Commissioner v. Phillips, 275 F. 2d 33 (C.A. 4, 1960), followed.
1Opinion of the Court
Dawson, Judge:
Respondent determined a deficiency in income tax for the taxable year 1956 in the amount of $1,131.85.
The only issue presented in this case is whether the petitioner, Bolling Jones, Jr., realized a long-term capital gain or ordinary income upon the assignment by him to the Fulton National Bank of Atlanta of a life insurance endowment policy.
FINDINGS OF FACT.
Most of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached thereto are incorporated herein by reference.
Bolling Jones, Jr., and Dorothy H. Jones are husband and wife residing in…
2Cases cited5 opinions
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Arnfeld v. United StatesUnited States Court of Claims · 1958
- Phillips v. CommissionerUnited States Tax Court · 1958
- Ellis Campbell, Jr. And Chester Usry, District Directors, Internal Revenue Service v. Lema Parker BagleyCourt of Appeals for the Fifth Circuit · 1960
3Cited by19 opinions
- S. C. Johnson & Son, Inc. v. CommissionerUnited States Tax Court · 1975
- Cohen v. CommissionerUnited States Tax Court · 1963
- Friedman v. CommissionerUnited States Tax Court · 1963
- Morgan Guaranty Trust Co. of New York v. United StatesUnited States Court of Claims · 1978
- Jones v. CommissionerUnited States Tax Court · 1963
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