Parshelsky v. Commissioner
United States Board of Tax Appeals
Held, that under reciprocal annuity contracts purchased by the petitioner and his brother, pursuant to agreement at a time when the brothers were indebted and involved in contentions as to taxes, the petitioner is taxable upon 3 per centum of the consideration in fact paid by him for life annuities applied for by his brother, but payable to petitioner, and refund annuities contingently payable to his estate, and upon the entire amount received by the petitioner from annuity…
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Held, that under reciprocal annuity contracts purchased by the petitioner and his brother, pursuant to agreement at a time when the brothers were indebted and involved in contentions as to taxes, the petitioner is taxable upon 3 per centum of the consideration in fact paid by him for life annuities applied for by his brother, but payable to petitioner, and refund annuities contingently payable to his estate, and upon the entire amount received by the petitioner from annuity contracts transferred to him by his brother, the entire consideration paid by the petitioner for such transfer having…
1Opinion of the Court
MOSES L. PARSHELSKY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Parshelsky v. Commissioner
Docket No. 103476.
United States Board of Tax Appeals
46 B.T.A. 456; 1942 BTA LEXIS 862;
February 26, 1942, promulgated
Held, that under reciprocal annuity contracts purchased by the petitioner and his brother, pursuant to agreement at a time when the brothers were indebted and involved in contentions as to taxes, the petitioner is taxable upon 3 per centum of the consideration in fact paid by him for life annuities applied for by his brother, but payable to petitioner, and refund annuities…
2Cases cited1 opinion
- Parshelsky v. CommissionerUnited States Board of Tax Appeals · 1942