Legal Opinion

Frost v. Commissioner

United States Tax Court

Decided April 17, 1969No. Docket No. 6054-66PublishedCited by 15 opinions

Held, payments by an employer of life insurance premiums on policies covering the life of an employee, where the annual increase in the cash surrender value accrues to the benefit of the employee and in addition he receives annual insurance protection for himself and family, result in a present economic benefit to such employee, and are includable in his gross income as additional compensation pursuant to the provisions of sec. 61(a), I.R.C. 1954.

1Opinion of the Court

OPINION

Sterrett, Judge:

Respondent determined deficiencies in income tax for the calendar years 1962, 1963, and 1964 in the amounts of $1,875.29, $1,573.56, and $1,518.87, respectively. The proceeding was submitted under Rule 30 of the Court’s Rules of Practice.

The error assigned by petitioners for 1962 is as follows: “(a) The erroneous and illegal finding that petitioners realized taxable income from the payment by his employer of life insurance premiums in the amount of $5,365.58 during 1962.”

Identical assignments, except for the year therein stated, were made for 1963 and 1964, respectively.

2Cases cited24 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Commissioner v. LoBueSupreme Court of the United States · 1956
  3. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  4. Commissioner v. SmithSupreme Court of the United States · 1945
  5. Schulde v. CommissionerSupreme Court of the United States · 1963

19 more not listed; retrieve them via the Exa API.

3Cited by15 opinions

  1. Sibla v. CommissionerUnited States Tax Court · 1977
  2. Goldsmith v. United StatesUnited States Court of Claims · 1978
  3. Richardson v. CommissionerUnited States Tax Court · 1975
  4. Genshaft v. CommissionerUnited States Tax Court · 1975
  5. Centre v. CommissionerUnited States Tax Court · 1970

10 more not listed; retrieve them via the Exa API.

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