Steven H. and Anna J. Jensen - Page 3

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               Respondent determined a deficiency in petitioners’ Federal             
          income tax of $2,730 for the taxable year 2000.                             
               The issue for decision is whether a distribution of $9,7602            
          resulting from the surrender of a whole life insurance policy is            
          includable in petitioners’ gross income.  We hold that it is.               
          Background                                                                  
               This case was submitted fully stipulated under Rule 122, and           
          the facts stipulated are so found.  We incorporate by reference             
          the parties’ stipulation of facts and accompanying exhibits.                
               At the time that the petition was filed, petitioners resided           
          in Woodburn, Oregon.  References to petitioners individually are            
          to Mr. Jensen or Mrs. Jensen.                                               
               Mr. Jensen is a retired certified public accountant and                
          former partner at the accounting firm of Harden, Swisher, and               
          Jensen.  As early as 1956, the firm had purchased several term              
          life insurance policies, which were cross-owned by and insured              
          the various partners.  Although not clearly explained in the                
          record, some of the term life insurance policies that insured Mr.           
          Jensen were converted into a whole life insurance policy bearing            
          No. 264261 (the policy).  The policy was issued on May 1, 1963,             
          by the Occidental Life Insurance Co. of California on the life of           
          Mr. Jensen in the face amount of $50,000 naming Mrs. Jensen as              




               2  All amounts are rounded to the nearest dollar.                      




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