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CARD v. COMMISSIONER

Docket Nos. 35870, 35871.

20 T.C. 620 (1953)

F. E. CARD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. W. S. ADAMS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 17, 1953.

Attorney(s) appearing for the Case

Thomas M. Davies, Esq., and Oscar R. Martin, C. P. A., for the petitioners.

Mark Townsend, Esq., for the respondent.

These cases have been duly consolidated for hearing and opinion. The respondent has determined deficiencies in income tax for the year 1945 against petitioner F. E. Card in the amount of $7,369.80 and against petitioner W. S. Adams in the amount of $3,935.91. Two questions are presented for decision: (1) Did petitioners F. E. Card and W. S. Adams realize taxable income on the receipt by them in 1945 of the cash surrender value of endowment life insurance policies upon the...

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