Legal Opinion · Dissent

London Shoe Co. v. Commissioner of Internal Revenue

Court of Appeals for the Second Circuit

Decided December 9, 1935No. 116Published

1DissentManton, Circuit Judge

In 1924 petitioner insured the life of one of its officers for $100,000. The petitioner was designated as the beneficiary and paid the gross annual premiums of $9,097 for seven years, or a total of $63,679. Of this sum $13,117 was received hack as dividends, leaving as the sum paid for insurance $50,562. The policy was surrendered and canceled in 1931 and the petitioners received its surrender value $24,600.

The petitioner claims a loss in 1931 of the difference between the net premiums paid and the cash surrender value in the sum of $25,962. The Board of Tax Appeals sustained the disallowance…

2Cases cited5 opinions

  1. Lucas v. AlexanderSupreme Court of the United States · 1929
  2. Forbes Lithograph Mfg. Co. v. WhiteDistrict Court, D. Massachusetts · 1930
  3. Appeal of Standard Brewing Co.United States Board of Tax Appeals · 1927
  4. Century Wood Preserving Co. v. Commissioner of Int. Rev.Court of Appeals for the Third Circuit · 1934
  5. Keystone Consol. Publishing Co. v. CommissionerUnited States Board of Tax Appeals · 1932

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