United States Tax Court September 17, 1980, Docket No. 2393-78 (Johnson v. Commissioner)

lead-opinion

Irwin, Judge:

By letter dated December 13, 1977, respondent determined deficiencies in petitioners’ 1974 and 1975 income taxes of $1,237 and $3,005, respectively. The only issue for our decision is whether payments of premiums on certain policies insuring the life of petitioner, Howard Johnson, by a corporation in which petitioners are shareholders, constitute income to petitioners.