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Glassner v. Commissioner of Internal Revenue

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT


decided: March 28, 1966.

RICHARD M. GLASSNER AND SYLVIA B. GLASSNER, PETITIONERS,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

Staley, Smith and Freedman, Circuit Judges.

Author: Per Curiam

The Tax Court sustained deficiencies in the petitioners' income taxes for the years 1958, 1959 and 1960. It held that payments made by the husband taxpayer for premiums on life insurance policies which he obtained to secure his debts were not deductible because he was a beneficiary of the policies. Internal Revenue Code of 1954, ยง 264(a)(1).*fn1

It would serve no useful purpose to review the factual details of the argument here presented and the unfortunate position in which the husband taxpayer found himself.

On a careful consideration of the arguments made and of the briefs and record, it is clear that the decision of the Tax Court was correct.

The decision of the Tax Court therefore will be affirmed.

Disposition

The decision of the Tax Court therefore will be affirmed.


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