Dean v. Commissioner
United States Tax Court
1. In 1955 petitioners each obtained loans on insurance policies which each held on the other's life. Soon thereafter, petitioners each assigned the insurance policies involved to their children.
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1. In 1955 petitioners each obtained loans on insurance policies which each held on the other's life. Soon thereafter, petitioners each assigned the insurance policies involved to their children. After the assignments, petitioners continued to pay the interest on the insurance loans during the remainder of 1955 and all of 1956. Held, petitioners may not deduct interest paid or accrued on insurance loans after the date of assignment of the beneficial ownership of the insurance policies to their children. Cf. Agnes I. Fox, 43 B.T.A. 895. 2. During 1955 and 1956 petitioners had outstanding…
1Opinion of the Court
OPINION.
Kaum, Judge:
The Commissioner determined deficiencies in income tax against petitioners for 1955 and 1956 in the amounts of $13,875.61 and $16,383.86, respectively. Petitioners are husband and wife; they filed joint returns for 1955 and 1956 with the director of internal revenue at Wilmington, Delaware. To the extent that the deficiencies still remain in controversy they raise the question whether petitioners were entitled to deduct as interest the amounts of $9,243.38 in 1955 and $26,912.02 in 1956 representing interest on loans on life insurance policies which had accrued and which…
2Cases cited18 opinions
- Louis Greenspon v. Commissioner of Internal Revenue, (Three Cases). Anna Greenspon v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- Greenspon v. CommissionerUnited States Tax Court · 1954
- Board of Assessors of the Parish v. New York Life InsuranceSupreme Court of the United States · 1910
- D. Loveman & Son Export Corp. v. CommissionerUnited States Tax Court · 1960
- Silverman v. CommissionerUnited States Tax Court · 1957
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- United States v. John William Gotcher Et Ux.Court of Appeals for the Fifth Circuit · 1968
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