Revenue Ruling 71-463 Overruled: Why and What Now
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Authors
McGrevey, Dan T.
Issue Date
1972
Volume
5
Issue
Type
Journal Article
Language
Keywords
Alternative Title
Abstract
INTRODUCTION|The Internal Revenue Service (Service), under the guise of Internal Revenue Ruling 71-463, enacted a significant impediment to the use of whole life insurance by closely-held corporations on the lives of their majority stockholders. While that ruling has recently been withdrawn by Revenue Ruling 72-167, the ultimate disposition of the problem is still not apparent.|The purpose of this article is threefold: First, to familiarize the reader with Revenue Ruling 71-463 and the relevant statutes, regulations, and tax consequences that would have resulted had it not been withdrawn; next, to examine previous case law and the arguments that have been raised against the ruling and which probably led to its withdrawal; and finally, to engage in speculation regarding what the future might hold in the way of new rulings or regulations which could bring about a more equitable and acceptable result...
Description
Citation
5 Creighton L. Rev. 315 (1971-1972)
Publisher
Creighton University School of Law