Appeal of Kline

Board of Tax Appeals

Appeal of Kline

3 B.T.A. 1138

CourtUnited States Board of Tax Appeals

DecidedApril 1, 1926

DocketDocket No. 5284

StatusPublished

Cited by2 cases

This text of 3 B.T.A. 1138 (Appeal of Kline) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeal of Kline, 3 B.T.A. 1138 (bta 1926).

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Opinion

FINDINGS OF FACT.

The taxpayer was the insured under policy No. 3377217, issuec 'by the New York Life Insurance Co. on November 29, 1902. The face value of the policy was $10,000. Under its terms 10 annua' premiums of $965.20 each were paid. The policy was fully paic up prior to March 1, 1913. No dividends or other distributions were made upon the policy prior to November 11, 1922, on whicl date the taxpayer received in settlement of the policy $14,830.10 The cash surrender value of the policy on March 1, 1913, was $9,070 The total amount of premiums paid on the policy amounted tc $9,652. The Commissioner based his computation of profit upor a value on March 1, 1913, of $9,070, the cash surrender value.

The deficiency for the year 1922 is $376.13. Order of redetermination will be entered accordingly.

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FINDINGS OF FACT.

The taxpayer was the insured under policy No. 3377217, issuec 'by the New York Life Insurance Co. on November 29, 1902. The face value of the policy was $10,000. Under its terms 10 annua' premiums of $965.20 each were paid. The policy was fully paic up prior to March 1, 1913. No dividends or other distributions were made upon the policy prior to November 11, 1922, on whicl date the taxpayer received in settlement of the policy $14,830.10 The cash surrender value of the policy on March 1, 1913, was $9,070 The total amount of premiums paid on the policy amounted tc $9,652. The Commissioner based his computation of profit upor a value on March 1, 1913, of $9,070, the cash surrender value.

The deficiency for the year 1922 is $376.13. Order of redetermination will be entered accordingly.

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3 B.T.A. 1138, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeal-of-kline-bta-1926.

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