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stated that he had never questioned any of the information
provided by the statements prior to his cancellation of the
policies. At trial, petitioner presented no evidence other than
undocumented and uncorroborated assertions to establish that
petitioners had a greater investment in the five surrendered life
insurance policies than the amounts computed by Northwestern.
Petitioner failed to show that Northwestern’s records were not
correct and that respondent’s determination was not correct.
Accordingly, respondent’s determination that petitioners must
include $8,786 in gross income with respect to the five
surrendered life insurance policies is sustained.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011