Thornley v. Commissioner
United States Tax Court
Held, petitioner, a cash basis taxpayer, received a taxable dividend in 1958 when he constructively received three life insurance policies which were owned by his controlled corporation.
1Opinion of the Court
Charles J. and Florence Thornley, Petitioners, v. Commissioner of Internal Revenue, Respondent
Thornley v. Commissioner
Docket No. 385-62
United States Tax Court
41 T.C. 145; 1963 U.S. Tax Ct. LEXIS 28;
October 30, 1963, Filed
Decision will be entered under Rule 50.
Held, petitioner, a cash basis taxpayer, received a taxable dividend in 1958 when he constructively received three life insurance policies which were owned by his controlled corporation.
James R. McGowan, for the petitioners.
Joseph W. Salus II, for the respondent.
Fay, Judge.
FAY
OPINION
The respondent determined a deficiency in the…
2Cases cited1 opinion
- Thornley v. CommissionerUnited States Tax Court · 1963