Legal Opinion

Pearlman v. Commissioner

United States Tax Court

Decided September 27, 1944No. Docket No. 112500Published

1. A resident of Pennsylvania, after becoming hopelessly insolvent, designated his wife as first beneficiary in several policies of insurance on his life, in substitution for his executors, administrators, or assigns. At the time of his death the insured was insolvent. Proceedings were then pending involving deficiencies in his income tax for several years. The proceedings were dismissed and the deficiencies were upheld.

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1. A resident of Pennsylvania, after becoming hopelessly insolvent, designated his wife as first beneficiary in several policies of insurance on his life, in substitution for his executors, administrators, or assigns. At the time of his death the insured was insolvent. Proceedings were then pending involving deficiencies in his income tax for several years. The proceedings were dismissed and the deficiencies were upheld. After the death of the insured the insurance companies issued claim settlement certificates in the aggregate amount of more than $ 200,000, under which decedent's widow is…

1Opinion of the Court

Florence Pearlman, Transferee, Petitioner, v. Commissioner of Internal Revenue, Respondent

Pearlman v. Commissioner

Docket No. 112500

United States Tax Court

4 T.C. 34; 1944 U.S. Tax Ct. LEXIS 56;

September 27, 1944, Promulgated

Decision will be entered under Rule 50.

1. A resident of Pennsylvania, after becoming hopelessly insolvent, designated his wife as first beneficiary in several policies of insurance on his life, in substitution for his executors, administrators, or assigns. At the time of his death the insured was insolvent. Proceedings were then pending involving deficiencies in his income…

2Cases cited24 opinions

  1. Erie Railroad v. TompkinsSupreme Court of the United States · 1938
  2. Higgins v. SmithSupreme Court of the United States · 1940
  3. Phillips v. CommissionerSupreme Court of the United States · 1931
  4. Blair v. CommissionerSupreme Court of the United States · 1937
  5. Helvering v. StuartSupreme Court of the United States · 1942

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