Legal Opinion

Yarnall v. Commissioner

United States Tax Court

Decided October 9, 1947No. Docket No. 12998PublishedCited by 16 opinions

Income -- Nondeductible Item -- Premiums on Life Insurance -- Section 24 (a) (4). -- Premiums on life insurance upon the life of a debtor-partner paid by the creditor-partner are nondeductible under section 24 (a) (4), I. R. C.

1Opinion of the Court

OPINION.

Murdock, Judge:

The petitioner argues that the premiums here in question are deductible under section 23 (a) (1) (A) or (a) (2), since they were paid by a creditor to obtain some collateral security for an indebtedness which exceeded the face amount of the policies. He also argues that the deductions are not to be disallowed by reason of section 24 (a) (4), which provides:

* * * no deduction shall in any case be allowed in respect of—(4) Premiums paid on any life insurance policy covering the life of any officer or employee, or of any person financially interested in any trade or…

2Cases cited1 opinion

  1. Harrison v. Northern Trust Co.Supreme Court of the United States · 1943

3Cited by16 opinions

  1. Cuddihy v. CommissionerUnited States Tax Court · 1959
  2. Keefe v. CommissionerUnited States Tax Court · 1950
  3. Estate of Jones v. CommissionerUnited States Tax Court · 1971
  4. United States v. Northumberland Ins. Co., Ltd.District Court, D. New Jersey · 1981
  5. Gage Bros. & Co. v. CommissionerUnited States Tax Court · 1949

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