Prunier v. Commissioner
United States Court of Appeals for the First Circuit
248 F.2d 818 (1957)
- Written by Heather Ryfa, JD
Facts
Joseph Prunier and his brother, Henry Prunier (plaintiffs), were the controlling shareholders in a closely held corporation, J.S. Prunier & Sons, Inc. J.S. Prunier & Sons paid the premium on life-insurance policies for the brothers for eight years; each brother was the beneficiary for the other. The corporate books contained an entry indicating that upon the death of one of the Pruniers, the life-insurance proceeds would go to the corporation to buy out the interest of the party who died. The corporation reported the cost of the policies on its tax returns. The commissioner of the Internal Revenue Service (defendant) assessed an income tax deficiency against Henry and Joseph Prunier for the premiums of life-insurance policies paid by J.S. Prunier & Sons. The Pruniers appealed to the United States Tax Court, which ruled in favor of the commissioner. The Pruniers appealed to the United States Court of Appeals for the First Circuit.
Rule of Law
Issue
Holding and Reasoning (Magruder, C.J.)
What to do next…
Here's why 899,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 47,000 briefs, keyed to 994 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
