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CASALE v. COMMISSIONER

Docket No. 54287.

26 T.C. 1020 (1956)

ORESTE CASALE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 12, 1956.

Attorney(s) appearing for the Case

Alexander D. Hanko, Esq., for the petitioner.

A. Jesse Duke, Jr., Esq., for the respondent.

OPINION.

RICE, Judge:

This proceeding involves a deficiency in income taxes of $1,953.14 for the year 1950 determined by the respondent against Oreste Casale.

The sole issue is whether the sum of $6,839.50 paid by O. Casale, Inc., as the annual premium upon an insurance policy on the life of petitioner, represented a distribution to him of a taxable dividend under section 115 (a)1 of the Internal Revenue Code of...

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