Legal Opinion

Boston Safe Deposit & Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided May 15, 1934No. Docket No. 49272Published

1. Where partnership agreement provided for life insurance to be carried on lives of general partners, premiums to be paid by partnership, policy to be held by and any loans to be for benefit of partnership, insured partner to designate and successively change beneficiaries, but, upon death of insured partner and payment of proceeds to designated beneficiaries, capital account of deceased partner was debited with the amount of such proceeds and capital accounts of surviving…

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1. Where partnership agreement provided for life insurance to be carried on lives of general partners, premiums to be paid by partnership, policy to be held by and any loans to be for benefit of partnership, insured partner to designate and successively change beneficiaries, but, upon death of insured partner and payment of proceeds to designated beneficiaries, capital account of deceased partner was debited with the amount of such proceeds and capital accounts of surviving partners credited with same amount in proportion to their interests in the partnership, held, full partnership interest…

1Opinion of the Court

BOSTON SAFE DEPOSIT AND TRUST COMPANY AND C. OLIVER WELLINGTON, EXECUTORS OF THE WILL OF CLINTON H. SCOVELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Boston Safe Deposit & Trust Co. v. Commissioner

Docket No. 49272.

United States Board of Tax Appeals

30 B.T.A. 679; 1934 BTA LEXIS 1283;

May 15, 1934, Promulgated

1. Where partnership agreement provided for life insurance to be carried on lives of general partners, premiums to be paid by partnership, policy to be held by and any loans to be for benefit of partnership, insured partner to designate and successively change…

2Cases cited6 opinions

  1. Ithaca Trust Co. v. United StatesSupreme Court of the United States · 1929
  2. Porter v. CommissionerSupreme Court of the United States · 1933
  3. Humes v. United StatesSupreme Court of the United States · 1928
  4. United States v. Provident Trust Co.Supreme Court of the United States · 1934
  5. Moore v. CommissionerUnited States Board of Tax Appeals · 1930

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