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PEOPLES FINANCE & THRIFT CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 13230.

184 F.2d 836 (1950)

PEOPLES FINANCE & THRIFT CO. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

November 3, 1950.

Attorney(s) appearing for the Case

Needham A. Graham, Jr., Birmingham, Ala., for petitioner.

Francis W. Sams, Ellis N. Slack, Lee A. Jackson, Special Assistants to Attorney General, Theron Lamar Caudle, Assistant Attorney General, Charles Oliphant, Chief Counsel, Rollin H. Transue, Special Attorney, Bureau of Internal Revenue, Washington, D. C., for respondent.

Before McCORD, BORAH and RUSSELL, Circuit Judges.

PER CURIAM.

We are of opinion the Tax Court correctly held that the amounts received by petitioner under certain health and accident insurance policies transferred to it for value constitute taxable income, and that they do not come within the purview of the exemption contained in Section 22 (b) (5) of the Internal Revenue Code, Title 26 U.S.C.A. § 22(b) (5).

We find no merit in the contention that because the amounts involved were "received through accident...

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