Legal Opinion

Estate of Horne v. Commissioner

United States Tax Court

Decided September 9, 1975No. Docket No. 3904-74Published

Petitioner Amelia S. Horne was a major shareholder of a corporation and the named beneficiary of two insurance policies on the life of decedent, her husband, who was a shareholder and officer of the same corporation. The corporation paid all policy premiums and retained all the incidents of ownership of the policies, including the right to change the beneficiary designation and the right to the cash surrender values.

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Petitioner Amelia S. Horne was a major shareholder of a corporation and the named beneficiary of two insurance policies on the life of decedent, her husband, who was a shareholder and officer of the same corporation. The corporation paid all policy premiums and retained all the incidents of ownership of the policies, including the right to change the beneficiary designation and the right to the cash surrender values. The proceeds were paid by the insurance company to Mrs. Horne on the death of the insured. Held, the proceeds were not a taxable constructive dividend distribution by the…

1Opinion of the Court

Estate of J. E. Horne, Deceased, Andrew Berry, Executor, and Amelia S. Horne, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Horne v. Commissioner

Docket No. 3904-74

United States Tax Court

64 T.C. 1020; 1975 U.S. Tax Ct. LEXIS 71;

September 9, 1975, Filed

Decision will be entered under Rule 155.

Petitioner Amelia S. Horne was a major shareholder of a corporation and the named beneficiary of two insurance policies on the life of decedent, her husband, who was a shareholder and officer of the same corporation. The corporation paid all policy premiums and retained all the…

2Cases cited6 opinions

  1. United States v. BessSupreme Court of the United States · 1958
  2. Casale v. CommissionerUnited States Tax Court · 1956
  3. Oreste Casale v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
  4. Francis H. W. Ducros and Phyllis A. Ducros v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1959
  5. Ducros v. CommissionerUnited States Tax Court · 1958

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