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Full-Text Articles in Tax Law
Federal Taxation - Transferee Liability Of Insurance Beneficiary, John Gelder S.Ed.
Federal Taxation - Transferee Liability Of Insurance Beneficiary, John Gelder S.Ed.
Michigan Law Review
Nearly six years after taxpayer died income tax deficiencies were determined against his estate. Since his estate was insolvent the Commissioner sought to impose transferee liability under section 311 of the 1939 code (now I.R.C. section 6901) on plaintiff, taxpayer's widow, as beneficiary of" her husband's life insurance. The Tax Court, applying federal law, held plaintiff liable for the entire deficiency since the proceeds received by her exceeded that amount. The court of appeals, applying state law, reversed and ruled that the beneficiary was not a "transferee" within the meaning of section 311 even to the extent of the cash …
Taxation - Federal Estate Tax - Insurance And Annuity Combinations, John B. Schwemm S.Ed.
Taxation - Federal Estate Tax - Insurance And Annuity Combinations, John B. Schwemm S.Ed.
Michigan Law Review
Decedent, aged seventy-six, invested in three single premium life insurance policies. Issuance of each was conditioned on the purchase of a single life, nonrefundable annuity of specified value, and no physical examination was required. Each combination was balanced so that the total premium, exclusive of loading charges, equalled the face value of the insurance. The resulting correlation between compound interest and annuity disbursements made the guaranteed payments to the annuitant correspond precisely with the expected income of a reinvestment of the entire deposit by the insurer. Decedent retained the annuity rights, but all present and future interests in the life …
Taxation - Federal Income Tax - Right Of Donee To Deduct Expense Of Contesting Gift Tax Asserted Against Donor, William J. Wise S.Ed.
Taxation - Federal Income Tax - Right Of Donee To Deduct Expense Of Contesting Gift Tax Asserted Against Donor, William J. Wise S.Ed.
Michigan Law Review
ln 1948 taxpayer's mother gave him 410 shares of stock in the family enterprise. She filed a gift tax return, but the government, in auditing it, disagreed with her valuation of the stock. Donor had no desire to contest the government's valuation, but since his mother and father still held substantial stock in the business which would eventually go to him, donee desired a lower valuation for estate tax evidentiary purposes. Allegedly fearing personal liability for any deficiency assessed against his mother as well as a lien against the corpus of the gift for any unpaid tax, he decided to …
Tax Management Of Estates And Trusts, By Practising Law Institute, Merle H. Miller
Tax Management Of Estates And Trusts, By Practising Law Institute, Merle H. Miller
Indiana Law Journal
No abstract provided.
Fundamentos Del Derecho Procesal Civil, Edward Ivan Cueva
Fundamentos Del Derecho Procesal Civil, Edward Ivan Cueva
Edward Ivan Cueva
No abstract provided.