McCamant v. Commissioner
United States Tax Court
1. Petitioners were owed $ 21,092.34 by J. S. Noill on account of business transactions and a personal loan. This indebtedness became worthless and was deducted by them from income with tax benefits. Without notifying petitioners, Noill secured insurance on his life naming them beneficiaries to the extent of any indebtedness which he might owe them at his death. Noill maintained ownership of the policy and paid all premiums thereon.
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1. Petitioners were owed $ 21,092.34 by J. S. Noill on account of business transactions and a personal loan. This indebtedness became worthless and was deducted by them from income with tax benefits. Without notifying petitioners, Noill secured insurance on his life naming them beneficiaries to the extent of any indebtedness which he might owe them at his death. Noill maintained ownership of the policy and paid all premiums thereon. Upon Noill's death, petitioners received $ 18,679.98 under the provisions of the policy in satisfaction of his indebtedness to them. Held, petitioners recovered…
1Opinion of the Court
Tietjens, Judge:
The Commissioner determined deficiencies in income tax for the years and in the amounts as set forth below:
Year Deficiency
1953 _$4,783. 92
1954 _ 211.76
1955 _ 9, 506. 75
By amended answer respondent seeks an increased deficiency for the taxable year 1954.
The issues for decision are: (1) Whether recovery of indebted-nesses previously deducted by petitioners were tax benefits constituted a taxable event where the recovery was effected by payment to the petitioners, as creditors and beneficiaries, of a portion of the proceeds of a life insurance contract on the life of the deceased…
2Cases cited11 opinions
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
- Black Motor Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Block v. CommissionerUnited States Board of Tax Appeals · 1939
- Union Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1940
6 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Anders v. CommissionerUnited States Tax Court · 1967
- Handelman v. CommissionerUnited States Tax Court · 1961
- Harrison v. CommissionerUnited States Tax Court · 1973
- Independent Cooperative Milk Producers Asso. v. CommissionerUnited States Tax Court · 1981
- Liberty Finance Service, Inc. v. CommissionerUnited States Tax Court · 1960
21 more not listed; retrieve them via the Exa API.