Legal Opinion

Enright v. Commissioner

United States Tax Court

Decided September 7, 1971No. Docket No. 3913-69PublishedCited by 7 opinions

The petitioner was an officer and a director of a corporation which paid group-term life insurance premiums for petitioner, in his capacity as a director of the corporation, pursuant to a plan to provide group-term life insurance protection for its directors, in addition to providing a separate plan of group-term life insurance coverage for its employees.

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The petitioner was an officer and a director of a corporation which paid group-term life insurance premiums for petitioner, in his capacity as a director of the corporation, pursuant to a plan to provide group-term life insurance protection for its directors, in addition to providing a separate plan of group-term life insurance coverage for its employees. Held, that the premiums paid by the corporation to provide the petitioner with group-term life insurance coverage in his capacity as a director are not subject to the limited exclusion allowed by sec. 79(a), I.R.C. 1954, as premiums paid by…

1Opinion of the Court

OPINION

Hoyt, Judge:

The Commissioner determined deficiencies in the petitioners’ Federal income taxes in the amount of $314.88 for the calendar year 1966 and $361.28 for the calendar year 1967. The issue presented is whether certain group-term life insurance premiums paid by a corporation for a life insurance policy on the life of a member of its board of directors are includable in the director’s gross income.

All of the facts have been stipulated and the stipulation of facts and exhibits attached thereto are incorporated herein by this reference. The petitioners, Maurice A. Enright and…

2Cases cited7 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Great Western Power Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
  3. Commissioner of Internal Revenue v. BonwitCourt of Appeals for the Second Circuit · 1937
  4. Adams v. CommissionerUnited States Board of Tax Appeals · 1929
  5. Yuengling v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1934

2 more not listed; retrieve them via the Exa API.

3Cited by7 opinions

  1. Dawson v. CommissionerUnited States Tax Court · 1972
  2. Whitcomb v. CommissionerUnited States Tax Court · 1983
  3. N. W. D. Inv. Co. v. CommissionerUnited States Tax Court · 1982
  4. Whipple Chrysler-Plymouth v. CommissionerUnited States Tax Court · 1972
  5. Dawson v. CommissionerUnited States Tax Court · 1972

2 more not listed; retrieve them via the Exa API.

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