Legal Opinion
Henry C. Minchin v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 20, 1964No. 28508_1PublishedCited by 29 opinions
1Opinion of the Court
MARSHALL, Circuit Judge.
This case presents the familiar question whether amounts paid as “interest” to a life insurance company which issued a single-premium annuity policy to the taxpayer, and then proceeded to “loan” him back amounts up to the cash or redemption value of the policy without any other security or recourse on the note, are deductible under sections 23(b) of the Internal Revenue Code of 1939 and 163.(a) of the 1954 Code. Or, as the Supreme Court put it in Knetsch v. United States, 364 U.S. 128, 81 S.Ct. 132, 5 L.Ed.2d 128 (1960), did the transaction between the taxpayer and the…
2Cases cited11 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Hertz Corp. v. United StatesSupreme Court of the United States · 1960
6 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- International Business MacHines Corporation v. The United StatesUnited States Court of Claims · 1965
- Davis v. CommissionerUnited States Tax Court · 1976
- Karl F. Knetsch and Eva Fay Knetsch v. The United StatesUnited States Court of Claims · 1965
24 more not listed; retrieve them via the Exa API.