Canaday v. Guitteau

FORD, District Judge.

This appeal is from a judgment dismissing appellant’s petition by which he sought to recover certain federal income taxes paid for the years 1927, 1928, and 1929, on account of deficiency assessments by which certain premiums on appellant’s life insurance policies paid during those years by the United States Advertising Corporation, of which he was president and a large stockholder, were treated as income to him and so taxed.

Prior to July 11, 1927, upon his own application, appellant procured to be issued- certain insurance policies upon his life, upon which the…