Dodge v. Commissioner
United States Tax Court
Petitioner Charles Dodge engaged in an insurance speculation scheme under which he purchased an excessive number of hospital indemnification policies. Held: Petitioners have not established that the proceeds received under the hospital indemnification policies related to actual personal injuries or sickness. Accordingly, the proceeds are not excludable under sec. 104(a)(3), I.R.C. 1954, as amended.
1Opinion of the Court
SWIFT, Judge:
Respondent mailed petitioners separate notices of deficiency each dated January 16, 1987, determining deficiencies in and additions to petitioners’ respective individual Federal income taxes for 1981, 1982, 1983, and 1984, as follows:
Charles Dodge
Additions to tax
Sec. Sec. Sec.1 Sec. r2>
6654 6661(a) Year Deficiency 6651(a)(1) 6653(a)(1) Si
$1,110.99 1981 $14,499.10 $3,624.78 $724.96 *
2,312.48 $5,938.03 1982 23,752.12 5,938.03 1,187.61
4,165.57 17,018.20 1983 68,072.79 17,018.20 3,403.64
3,964.06 15,762.61 1984 63,050.44 15,762.61 3,152.52
Christine Y. Roberts
Additions to tax
Sec.6661(a)…
2Cases cited8 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Grosshandler v. CommissionerUnited States Tax Court · 1980
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Zmuda v. CommissionerUnited States Tax Court · 1982
- Nell La Compte Reaves, as of the Will of Jesse Ullman Reaves, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1961
3 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Charles Dodge Christine Y. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1993
- Bagby v. CommissionerUnited States Tax Court · 1994
- Thompson v. Comm'rUnited States Tax Court · 2011
- Muncy v. Comm'rUnited States Tax Court · 2017
- Batsch v. Comm'rUnited States Tax Court · 2016
19 more not listed; retrieve them via the Exa API.