Landfield Finance Company v. United States

HASTINGS, Senior Circuit Judge.

Plaintiff-taxpayer Landfield Finance Company brought this action in the district court seeking an income tax refund in the amount of $6,626.48 which it alleges was illegally and erroneously assessed and collected. The district court entered judgment adverse to taxpayer and this appeal followed. We affirm.

The sole issue on appeal is whether the proceeds of a life insurance policy were “received [by plaintiff-taxpayer-creditor] * * * under a life insurance contract * * * by reason of the death of the insured [debtor]” within the meaning of Section 101(a) (1) of…