Legal Opinion

Estate of Snider v. Commissioner

United States Tax Court

Decided February 27, 1959No. Docket No. 58199Published

Insured's election before maturity under insurance company's annuity policy to leave principal sum on deposit and receive monthly installments of principal augmented by interest and dividends, held, not to result in constructive receipt 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, Lena Snider, Executrix, and Lena Snider, Individually, Petitioners, v. Commissioner of Internal Revenue, Respondent

Estate of Snider v. Commissioner

Docket No. 58199

United States Tax Court

31 T.C. 1064; 1959 U.S. Tax Ct. LEXIS 226;

February 27, 1959, Filed

Decision will be entered under Rule 50.

Insured's election before maturity under insurance company's annuity policy to leave principal sum on deposit and receive monthly installments of principal augmented by interest and dividends, held, not to result in constructive receipt of difference between premiums previously paid…

Also in this document: Dissent.

2Cases cited12 opinions

  1. Helvering v. HelmholzSupreme Court of the United States · 1935
  2. Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
  3. White v. PoorSupreme Court of the United States · 1935
  4. Thornley v. Commissioners of Internal RevenueCourt of Appeals for the Third Circuit · 1945
  5. Thornley v. CommissionerUnited States Tax Court · 1943

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