Legal Opinion

Estate of Snider v. Commissioner

United States Tax Court

Decided November 5, 1962No. Docket No. 88472Published

Insured's election in 1950, before maturity under insurance company's annuity policy, to leave cash surrender value (principal sum) on deposit and receive monthly installments of principal augmented by interest and dividends, held, not to result in constructive receipt in taxable year 1951 of difference between premiums previously paid and cash surrender value, insurance company not being required to pay principal in taxable year.

1Opinion of the Court

Estate of Harry Snider, Deceased, Lena Snider, Executrix, and Lena Snider, Surviving Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent

Estate of Snider v. Commissioner

Docket No. 88472

United States Tax Court

39 T.C. 341; 1962 U.S. Tax Ct. LEXIS 34;

November 5, 1962, Filed

Decision will be entered under Rule 50.

Insured's election in 1950, before maturity under insurance company's annuity policy, to leave cash surrender value (principal sum) on deposit and receive monthly installments of principal augmented by interest and dividends, held, not to result in constructive receipt in…

2Cases cited11 opinions

  1. Yagoda v. CommissionerUnited States Tax Court · 1962
  2. Thornley v. Commissioners of Internal RevenueCourt of Appeals for the Third Circuit · 1945
  3. Thornley v. CommissionerUnited States Tax Court · 1943
  4. National Metropolitan Bank v. United StatesUnited States Court of Claims · 1950
  5. Jacobs v. CommissionerUnited States Board of Tax Appeals · 1931

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