Thornley v. Commissioner
United States Tax Court
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
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Commonwealth v. Metropolitan Life InsuranceSupreme Court of Pennsylvania · 1916
- Barber's EstateSupreme Court of Pennsylvania · 1931
- Thornley v. CommissionerUnited States Tax Court · 1943
- State Ex Rel. Thornton v. Probate CourtSupreme Court of Minnesota · 1932
1 more not listed; retrieve them via the Exa API.