Thornley v. Commissioner
United States Tax Court
Held, petitioner, a cash basis taxpayer, received a taxable dividend in 1958 when he constructively received three life insurance policies which were owned by his controlled corporation.
1Opinion of the Court
OPINION
Fay, Judge:
The respondent determined a deficiency in the petitioners’ income tax in the amount of $5,168.15 for the taxable year 1958. The only issue for decision is whether the Thornley Supply Co. made a taxable distribution, consisting of eight insurance policies on the life of Charles J. Thornley, to its shareholder, Charles J. Thornley, in 1958.
All of the facts have been stipulated and are so found.
Charles J. Thornley (hereinafter referred to as petitioner) and Florence Thornley are husband and wife with residence at North Attleboro, Mass. They filed a joint income tax return for…
2Cases cited8 opinions
- Burnet v. WellsSupreme Court of the United States · 1933
- Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- Cohen v. CommissionerUnited States Tax Court · 1963
- Cummings v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1934
- Golden v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Thornley v. CommissionerUnited States Tax Court · 1963