Ostrov v. Commissioner
United States Tax Court
Petitioner applied for and received a policy of life insurance upon the life of her former husband prior to their divorce. She thereafter entered into an agreement with him that he would pay the premiums on the life insurance policy by borrowings, using the policy as collateral, such borrowings to always exceed the cash surrender value of the policy. The former husband also agreed to bequeath petitioner $ 150,000 by his will.
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Petitioner applied for and received a policy of life insurance upon the life of her former husband prior to their divorce. She thereafter entered into an agreement with him that he would pay the premiums on the life insurance policy by borrowings, using the policy as collateral, such borrowings to always exceed the cash surrender value of the policy. The former husband also agreed to bequeath petitioner $ 150,000 by his will. The $ 150,000 so bequeathed was to be lessened by any amount received by petitioner by way of life insurance proceeds. Respondent had determined a deficiency based upon…
1Opinion of the Court
OPINION
Withey Judge:
Deficiencies have been determined by respondent for the calendar years 1964 and 1965 in the income tax of petitioners in the respective amounts of $2,405.77 and $1,815.18. The only issue presented is whether respondent has erred in including in the gross income of petitioners amounts paid as insurance premiums by the former husband of Rena Ostrov upon a policy of life insurance wherein the former husband is the insured and she is designated the owner and sole beneficiary of the policy.
This case has been submitted as fully stipulated under Rule 30 of this Court and such…
2Cases cited8 opinions
- Carmichael v. CommissionerUnited States Tax Court · 1950
- Walsh v. Comm'rUnited States Tax Court · 1954
- Weil v. CommissionerUnited States Tax Court · 1954
- Stewart v. CommissionerUnited States Tax Court · 1947
- Blumenthal v. CommissionerUnited States Tax Court · 1949
3 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Wright v. CommissionerUnited States Tax Court · 1974
- Claus A. Cosman and Dorothy Cosman v. The United StatesUnited States Court of Claims · 1971
- Greenway v. CommissionerUnited States Tax Court · 1980
- Ostrov v. CommissionerUnited States Tax Court · 1969
- Wright v. CommissionerUnited States Tax Court · 1974