Thompson v. Commissioner
United States Tax Court
1. Petitioner was the sole beneficiary of two policies of insurance totaling $ 75,000 on the life of her deceased husband. The policies were pledged to a trust company as collateral security for debts of her husband totaling $ 33,194.91, evidenced by notes signed by petitioner as an accommodation party. Petitioner herself paid part of the debts and the balance was paid out of the proceeds of the policies.
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1. Petitioner was the sole beneficiary of two policies of insurance totaling $ 75,000 on the life of her deceased husband. The policies were pledged to a trust company as collateral security for debts of her husband totaling $ 33,194.91, evidenced by notes signed by petitioner as an accommodation party. Petitioner herself paid part of the debts and the balance was paid out of the proceeds of the policies. Petitioner received an assignment from the trust company of its claim against the estate. She also paid $ 15,440.65 for all other outstanding claims against the estate and became the sole…
1Dissent
BRUCE, ¡7.,
dissenting: As I view all of the facts and circumstances of this case, petitioner sustained a loss of $22,222.51 in 1945, which is deductible to the extent permitted by section 23 (k) (4) of the Internal Revenue Code.
Petitioner paid the creditors of her deceased husband’s estate an aggregate of $48,635.56 and received assignments from them of their claims against the estate. Being then the sole creditor of the estate she received in payment thereof $3,923.05 in cash and certain shares of stock representing minority holdings in small closely held corporations, comprising all the…
2Cases cited11 opinions
- Leslie v. CommissionerUnited States Tax Court · 1946
- Shiman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- American Cigar Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
- Sherman v. CommissionerUnited States Tax Court · 1952
- De Guebriant v. CommissionerUnited States Tax Court · 1950
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