- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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