Legal Opinion
Johnson v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided December 14, 1936No. 97PublishedCited by 63 opinions
1Opinion of the Court
SWAN, Circuit Judge.
The deficiency in dispute results from the disallowance of a deduction of $24,-000 claimed by the petitioner to have been paid as interest on his promissory note, and to be an allowable deduction from gross income under section 23(b) of the Revenue Act of 1928 (45 Stat. 799 [26 U.S.C.A. § 23 and note]). The facts reveal an ingenious attempt to reduce taxes by means of a plan which was intended to give the character of interest payments to money used to pay insurance premiums on policies upon the life of the petitioner. There were 15 such policies, all of them payable to…
2Cases cited11 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Chisholm v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
- Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1931
- Gannon v. . McGuireNew York Court of Appeals · 1899
- In Re the Transfer Tax Upon the Estate of SchmidlappNew York Court of Appeals · 1923
6 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Sun Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Skemp v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1948
- Lynch v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Broome v. United StatesUnited States Court of Claims · 1959
58 more not listed; retrieve them via the Exa API.