Kay v. Commissioner
United States Tax Court
Held: Petitioner-owners of annual-premium life insurance policies issued prior to August 6, 1963, entitled to deduct interest paid on policy loans issued under self-funding life insurance plan despite fact that petitioners' payments were made to a lending agency which purportedly loaned petitioners money on the security of the policies, and in turn paid the net premiums and interest on the policy loans to the insurance company with funds paid to it by petitioners,…
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Held: Petitioner-owners of annual-premium life insurance policies issued prior to August 6, 1963, entitled to deduct interest paid on policy loans issued under self-funding life insurance plan despite fact that petitioners' payments were made to a lending agency which purportedly loaned petitioners money on the security of the policies, and in turn paid the net premiums and interest on the policy loans to the insurance company with funds paid to it by petitioners, purportedly as interest on the loans from the lending agencies to petitioners. Petitioners admit that the purported loans from the…
1Opinion of the Court
OPINION
Drennen, Judge:
In these consolidated cases respondent determined deficiencies in petitioners’ income taxes as follows:
Docket No. Petitioner Riscal or calendar year ended— Deficiency
2002-63 Murray Kay and Ida Kay..... Dee. 81,1959. $768.74
2003-63 Plastic Glide Corp. (formerly Plastiglide Manufacturing Corp.) Dec. 81,1960_ July 31,1959_ July 31,1960. Aug. 1,1960, to Sept. 30,1960. 777.68 1.559.45 3,754.96 704.76
2004.63 Saul Bolton and Ethel Rose Bolton___ Dee. 31,1959. Dec. 31,1960.. 3.402.45 3,537 60
2005-63 Louis L. Colen, surviving husband, and Estate of Preda Colen, deceased, Louis L.…
2Cases cited9 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Dean v. CommissionerUnited States Tax Court · 1961
- Albert Gordon MacRae and Sheila MacRae v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- Joseph H. Bridges and Lillier J. Bridges v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
4 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Ellis Campbell, Jr., District Director of Internal Revenue v. Cen-Tex, Inc.Court of Appeals for the Fifth Circuit · 1967
- Minnis v. CommissionerUnited States Tax Court · 1979
- Salley v. CommissionerUnited States Tax Court · 1971
- Cecil H. Shirar and Jessie May Shirar v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1990
10 more not listed; retrieve them via the Exa API.