Moseley v. Commissioner
United States Tax Court
Petitioner received a distribution under the "special reserve" provision of a life insurance contract which provided, in addition, for a $ 5,000 life insurance benefit. Under the policy, a portion of the premiums paid during the second through fifth years of the policy was credited to a special reserve account. The amount of the special reserve account was combined with amounts paid by other policyholders in a fund which was invested in common stocks.
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Petitioner received a distribution under the "special reserve" provision of a life insurance contract which provided, in addition, for a $ 5,000 life insurance benefit. Under the policy, a portion of the premiums paid during the second through fifth years of the policy was credited to a special reserve account. The amount of the special reserve account was combined with amounts paid by other policyholders in a fund which was invested in common stocks. In the 20th year of the policy, a distribution was paid on each policy if the following conditions were met: the insured was then living, the…
1Opinion of the Court
Ned W. Moseley and Mabel Bowman Moseley, Petitioners v. Commissioner of Internal Revenue, Respondent
Moseley v. Commissioner
Docket No. 925-76
United States Tax Court
72 T.C. 183; 1979 U.S. Tax Ct. LEXIS 135;
April 23, 1979, Filed
Decision will be entered under Rule 155.
Petitioner received a distribution under the "special reserve" provision of a life insurance contract which provided, in addition, for a $ 5,000 life insurance benefit. Under the policy, a portion of the premiums paid during the second through fifth years of the policy was credited to a special reserve account. The amount of the…
2Cases cited10 opinions
- Fidelity-Philadelphia Trust Co. v. SmithSupreme Court of the United States · 1958
- Helvering v. MeredithCourt of Appeals for the Eighth Circuit · 1944
- Edwin A. Gallun and Jane W. Gallun (Formerly Husband and Wife) v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Estate of Montgomery v. Comm'rUnited States Tax Court · 1971
- Estate of Lafayette Montgomery, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
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