Legal Opinion

Parshelsky v. Commissioner

United States Board of Tax Appeals

Decided February 26, 1942No. Docket No. 103476Published

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…

Read the full summary

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

  1. Parshelsky v. CommissionerUnited States Board of Tax Appeals · 1942

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API