Minnis v. Commissioner
United States Tax Court
The premiums on an employee annuity contract were paid by an employer and qualified for exclusion from the gross income of the employee under sec. 403(b), I.R.C. 1954. Held, a policy loan under the employee annuity contract was not includable in the employee's gross income as an amount received under the annuity contract. Sec. 72(e)(1)(B), I.R.C. 1954.
1Opinion of the Court
Tannenwald, Judge:
Respondent determined a deficiency of $1,670 in petitioners’ income tax for 1974. At issue is whether a policy loan against an employee annuity contract purchased by an employer is taxable income to the employee, where the premiums paid were not includable in the employee’s gross income.
FINDINGS OF FACT
Some of the facts were stipulated. The stipulation of facts, together with the exhibits attached thereto, is incorporated herein by this reference.
Petitioners Robert W. Minnis and Mary F. Minnis, husband and wife, filed a joint income tax return for the calendar year 1974 with…
2Cases cited21 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Helvering v. HorstSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Jarecki v. G. D. Searle & Co.Supreme Court of the United States · 1961
- Primuth v. CommissionerUnited States Tax Court · 1970
16 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Estate of Leach v. CommissionerUnited States Tax Court · 1984
- Beneficial Foundation, Inc. v. United StatesUnited States Court of Claims · 1985
- Silco, Inc. v. United StatesDistrict Court, N.D. Texas · 1984
- Cameron v. CommissionerUnited States Tax Court · 1983
- Ledger v. Comm'rUnited States Tax Court · 2011
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