- 2 - be entered is not reviewable by any other court, and this opinion should not be cited as authority. Respondent determined a deficiency in petitioners’ Federal income tax for the taxable year 2001 of $1,342. The issue for decision is whether a distribution of $8,944 resulting from the surrender of a life insurance policy is includable in petitioners’ gross income. We hold that it is. Background Some of the facts have been stipulated, and they 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 Santa Cruz, California. On July 17, 1987, Kenneth T. White (petitioner) acquired a universal life insurance policy (the policy) with Pacific Mutual Life Insurance Co. (Pacific Life). The policy entitled petitioner to withdraw funds against the policy’s accumulated value. The policy defined accumulated value as the net amount of premiums (premiums paid less premium load charge) plus interest and dividends earned minus deductions (e.g., withdrawal amounts, mortality charges, administrative charges, insurance loads, and rider chargers). The policy also entitled petitioner to borrow against the policy as collateral up to the loan value available. The policyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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