Estate of Snider v. Commissioner
United States Tax Court
Insured's election in 1950, before maturity under insurance company's annuity policy, to leave cash surrender value (principal sum) on deposit and receive monthly installments of principal augmented by interest and dividends, held, not to result in constructive receipt in taxable year 1951 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
opinion.
Arundell, Judge:
Respondent determined a deficiency in income tax for the calendar year 1951 in the amount of $12,517.26.
Three errors were assigned by petitioners as follows:(a) The Commissioner erred in determining that the Decision of the Tax Court of the United States in Estate of Harry Snider, 31 TC 1064, constituted a determination within the meaning of Section 1313 of the Internal Revenue Code of 1954.(b) The Commissioner erred in determining that the amount of $21,384.63 represents taxable income constructively received in the calendar year 1951.(c) The Commissioner erred in…
2Cases cited10 opinions
- Yagoda v. CommissionerUnited States Tax Court · 1962
- Thornley v. Commissioners of Internal RevenueCourt of Appeals for the Third Circuit · 1945
- Thornley v. CommissionerUnited States Tax Court · 1943
- National Metropolitan Bank v. United StatesUnited States Court of Claims · 1950
- Jacobs v. CommissionerUnited States Board of Tax Appeals · 1931
5 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Estate of Silverman v. CommissionerUnited States Tax Court · 1974
- Estate of Silverman v. CommissionerUnited States Tax Court · 1974
- Estate of Snider v. CommissionerUnited States Tax Court · 1962
- Thompson v. CommissionerUnited States Tax Court · 1964