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TOWNE v. COMMISSIONER

Docket No. 10924-79.

78 T.C. 791 (1982)

WILLIAM S. TOWNE AND MARJORIE H. TOWNE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 12, 1982.

Attorney(s) appearing for the Case

Walter V. Stafford, for the petitioners.

Rebecca T. Hill, for the respondent.

WHITAKER, Judge:*

Respondent determined a deficiency in petitioners' individual income tax for the calendar year 1975 in the amount of $17,668. The sole issue for decision is whether an individual term life insurance policy purchased by Mr. Towne's employer on his life is part of a plan of group insurance under section 79.1

FINDINGS OF FACT

Some of the facts have been stipulated and...

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