- 2 - Rule references are to the Tax Court Rules of Practice and Procedure. The issues remaining for decision are: (1) Whether petitioners are taxable on distributions totaling $38,117 from the termination of a life insurance policy and an endowment policy; (2) whether petitioners are entitled to deduct interest on amounts borrowed against these two policies; and (3) whether petitioners are liable for an accuracy-related penalty for a substantial understatement of income tax.1 FINDINGS OF FACT The parties have stipulated some of the facts, which are so found. The stipulation of facts with attached exhibits is incorporated herein by this reference. When they petitioned the Court, petitioners were married and resided in Dallas, Texas. In 1986, petitioner husband purchased a single premium life insurance policy from First Colony Life Insurance Co. (First Colony), paying a single premium of $25,000. On March 8, 1988, petitioner wife purchased a single premium endowment policy from National Western Life Insurance Co. (National Western), paying a single premium of $50,000. 1 Petitioners stipulated that they failed to report taxable interest income in the amount of $26 on their 1995 joint Federal income tax return.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011