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Taxation - Annuity Contracts - Federal Estate Tax, Charles J. O'Laughlin
Taxation - Annuity Contracts - Federal Estate Tax, Charles J. O'Laughlin
Michigan Law Review
The decedent purchased several single-premium annuity contracts, the annuity payments to be made to her for life, and after her death to a designated second annuitant for life. The Board of Tax Appeals ruled that the policy should not be taxed as a transfer to take effect at death. Held, on appeal, the interest passing to the second anuitant at the death of the decedent should be included in decedent's gross estate under the federal estate tax, since it falls within the provision taxing transfers intended to take effect in possession and enjoyment at or after the death of …
Taxation - Income Tax - Exemption Of Proceeds Of Insurance Policies Payable In The Form Of An Annuity, Wilbur Jacobs
Taxation - Income Tax - Exemption Of Proceeds Of Insurance Policies Payable In The Form Of An Annuity, Wilbur Jacobs
Michigan Law Review
Plaintiff was the beneficiary of a life insurance policy payable in equal installments over a period of twenty years. The deferred payments had been substituted for payment of the face amount of the policy through an option in the policy exercised by the insured a short time before his death. The Commissioner of Internal Revenue included in gross income the amount by which each payment exceeded one-twentieth of the face amount of the policy on the theory that this excess was interest and hence not within the statute exempting insurance from gross income. Plaintiff sued to recover the tax paid. …
Taxation - Income Tax - Inclusion Of Unpaid Dividends In Decedent's Income, Michigan Law Review
Taxation - Income Tax - Inclusion Of Unpaid Dividends In Decedent's Income, Michigan Law Review
Michigan Law Review
Decedent owned stock in a corporation whose board of directors declared a dividend on April 30, 1934, for the fiscal year ending January 31, 1935, payable to stockholders of record at such times and in such installments as the directors might determine. At the time of decedent's death, October 15, 1934, only one-half of the dividend had been paid to him, but the commissioner included in the gross income of the decedent for the taxable period prior to death the entire amount of the dividend declared. The Board of Tax Appeals reduced this amount to the portion of the dividend …