- 2 - Respondent determined for 1999 a deficiency in petitioner’s Federal income tax of $658. The issue for decision is whether $2,326.33 of interest distributed to petitioner from the Prudential Life Insurance Company is taxable as income to petitioner. Background The stipulation of facts and the exhibits received into evidence are incorporated herein by reference. Petitioner resided in Warren, Michigan, at the time the petition in this case was filed. In 1985, petitioner purchased a "variable/appreciable policy" (VAP) from the Prudential Life Insurance Company (Prudential). Petitioner believed it was an investment vehicle through which he could fund his retirement. At the time he purchased the VAP, petitioner also had an existing life insurance policy with Prudential. Petitioner agreed to have the premiums for the VAP paid through loans against the cash value of his existing life insurance policy and from investment earnings derived from the VAP. The VAP premiums, totaling $4,647.83, were paid by loans taken from the cash value of the life insurance policy. By 1987, the cash value of the life insurance policy had been borrowed in full. Petitioner was unemployed and unable to pay the premiums on the VAP which caused the policy to lapse.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011