Rugby Prods. v. Commissioner
United States Tax Court
P is a personal service corporation wholly owned by R, a professional entertainer, and her spouse (now deceased). P took out a disability income insurance policy on R payable to itself.
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P is a personal service corporation wholly owned by R, a professional entertainer, and her spouse (now deceased). P took out a disability income insurance policy on R payable to itself. Held, since any proceeds of the disability income policy would have been excludable from P's gross income under I.R.C. sec. 104(a)(3), the premiums which P paid were not allowable as a deduction, being allocable to a class of income exempt from income tax, as provided in I.R.C. sec. 265(a)(1). Held, further, P is not liable for the addition to tax for negligence under I.R.C. sec. 6653.
1Opinion of the Court
RUGBY PRODUCTIONS LTD., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Rugby Prods. v. Commissioner
Docket No. 11645-91
United States Tax Court
100 T.C. 531; 1993 U.S. Tax Ct. LEXIS 35; 100 T.C. No. 35; 16 Employee Benefits Cas. (BNA) 2722;
June 14, 1993, Filed
Decision will be entered under Rule 155.
P is a personal service corporation wholly owned by R, a professional entertainer, and her spouse (now deceased). P took out a disability income insurance policy on R payable to itself. Held, since any proceeds of the disability income policy would have been excludable from P's gross income…
2Cases cited5 opinions
- Bass v. John Hancock Mutual Life InsuranceCalifornia Supreme Court · 1974
- Peoples Finance & Thrift Co. v. CommissionerUnited States Tax Court · 1949
- Castner Garage, Ltd. v. CommissionerUnited States Board of Tax Appeals · 1940
- Rugby Prods. v. CommissionerUnited States Tax Court · 1993
- Peoples Finance & Thrift Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950