Mushro v. Commissioner
United States Tax Court
The three partners of a partnership had a buy-sell agreement to take effect upon the death of the first to die. They funded the agreement with insurance policies, owned by the partnership, on the life of each partner. Each partner's wife was the named beneficiary of the policy on his life.
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The three partners of a partnership had a buy-sell agreement to take effect upon the death of the first to die. They funded the agreement with insurance policies, owned by the partnership, on the life of each partner. Each partner's wife was the named beneficiary of the policy on his life. Held: When the first partner died, the realities of the situation were that the surviving partners received the insurance proceeds from the policy on the deceased partner's life and then paid them to the deceased partner's wife in exchange for the interest in the partnership to which she was entitled…
1Opinion of the Court
Victor G. Mushro and Luella Mushro, Petitioners v. Commissioner of Internal Revenue, Respondent; Louis A. Mushro and Anita A. Mushro, Petitioners v. Commissioner of Internal Revenue, Respondent
Mushro v. Commissioner
Docket Nos. 2101-66, 2102-66
United States Tax Court
50 T.C. 43; 1968 U.S. Tax Ct. LEXIS 146;
April 15, 1968, Filed
Decisions will be entered under Rule 50.
The three partners of a partnership had a buy-sell agreement to take effect upon the death of the first to die. They funded the agreement with insurance policies, owned by the partnership, on the life of each partner. Each partner's…
Also in this document: Concurrence.
2Cases cited3 opinions
- Orr Mills v. CommissionerUnited States Tax Court · 1958
- Legallet v. CommissionerUnited States Board of Tax Appeals · 1940
- Mushro v. CommissionerUnited States Tax Court · 1968