Legal Opinion

Genshaft v. Commissioner

United States Tax Court

Decided May 27, 1975No. Docket Nos. 9275-72, 9276-72Published

Held, petitioners must include in their gross income the value of the economic benefit received from the maintenance of certain whole life insurance policies by their family-owned corporation under a so-called "split-dollar" arrangement. Held, further, value determined through application of Rev. Rul. 55-713, 1955-2 C.B. 23. See Rev. Rul. 64-328, 1964-2 C.B. 11.

1Opinion of the Court

Arthur Genshaft and Leona Genshaft, Petitioners v. Commissioner of Internal Revenue, Respondent; David Genshaft and Anne Genshaft, Petitioners v. Commissioner of Internal Revenue, Respondent

Genshaft v. Commissioner

Docket Nos. 9275-72, 9276-72

United States Tax Court

64 T.C. 282; 1975 U.S. Tax Ct. LEXIS 140;

May 27, 1975, Filed

Decisions will be entered under Rule 155.

Held, petitioners must include in their gross income the value of the economic benefit received from the maintenance of certain whole life insurance policies by their family-owned corporation under a so-called "split-dollar"…

2Cases cited11 opinions

  1. Commissioner v. SmithSupreme Court of the United States · 1945
  2. Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
  3. Aetna Life Insurance v. DunkenSupreme Court of the United States · 1925
  4. Sandor v. CommissionerUnited States Tax Court · 1974
  5. Dean v. CommissionerUnited States Tax Court · 1961

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