Towne v. Commissioner
United States Tax Court
In 1975, the corporation employing petitioner as president purchased a $ 500,000 individual term life insurance policy on his life and named his wife as beneficiary.
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In 1975, the corporation employing petitioner as president purchased a $ 500,000 individual term life insurance policy on his life and named his wife as beneficiary. This policy was in addition to a group term life insurance policy that covered all employees of the corporation, including petitioner, and provided insurance coverage in the amount of 1 times salary, with a maximum coverage of $ 25,000. Held, the individual term life insurance policy is not part of a plan of group insurance under sec. 1.79-1(b)(1), Income Tax Regs., as in effect in 1975. Held, further, the requirement in the…
1Opinion of the Court
Whitaker, Judge: *
Respondent determined a deficiency in petitioners’ individual income tax for the calendar year 1975 in the amount of $17,668. The sole issue for decision is whether an individual term life insurance policy purchased by Mr. Towne’s employer on his life is part of a plan of group insurance under section 79.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and exhibits attached thereto are incorporated herein by reference.
William S. Towne (hereinafter petitioner) and Marjorie H. Towne, husband and wife, resided in Piedmont,…
2Cases cited2 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Frost v. CommissionerUnited States Tax Court · 1969
3Cited by7 opinions
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- N. W. D. Inv. Co. v. CommissionerUnited States Tax Court · 1982
- Estate of Worster v. CommissionerUnited States Tax Court · 1984
- Ruben De Los Santos & Martha De Los Santos v. CommissionerUnited States Tax Court · 2018
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