Legal Opinion

Thornley v. Commissioner

United States Tax Court

Decided June 25, 1943No. Docket No. 105554Published

1. Petitioner surrendered several endowment policies prior to their maturities and elected to receive the cash surrender values in equal installments over 20 years and 10 years, respectively.

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1. Petitioner surrendered several endowment policies prior to their maturities and elected to receive the cash surrender values in equal installments over 20 years and 10 years, respectively. Under the facts it is held, that the receipts in the taxable year were not annuity receipts within the intendment of section 22 (b) (2) of the Revenue Act of 1936, and no part of the amounts received in the taxable year are includable in gross income. 2. Petitioner was a member of a copartnership. Prior to the taxable year the copartnership ended its business, which was taken over by a newly formed…

1Opinion of the Court

George H. Thornley and Rebecca W. Thornley, Petitioners, v. Commissioner of Internal Revenue, Respondent

Thornley v. Commissioner

Docket No. 105554

United States Tax Court

2 T.C. 220; 1943 U.S. Tax Ct. LEXIS 118;

June 25, 1943, Promulgated

Decision will be entered under Rule 50.

1. Petitioner surrendered several endowment policies prior to their maturities and elected to receive the cash surrender values in equal installments over 20 years and 10 years, respectively. Under the facts it is held, that the receipts in the taxable year were not annuity receipts within the intendment of section 22 (b)…

Also in this document: Dissent.

2Cases cited6 opinions

  1. Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
  2. Commonwealth v. Metropolitan Life InsuranceSupreme Court of Pennsylvania · 1916
  3. Barber's EstateSupreme Court of Pennsylvania · 1931
  4. Thornley v. CommissionerUnited States Tax Court · 1943
  5. State Ex Rel. Thornton v. Probate CourtSupreme Court of Minnesota · 1932

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