TC Memo. 2012-244 - U.S. Tax Court
TC Memo. 2012-244 - U.S. Tax Court
TC Memo. 2012-244 - U.S. Tax Court
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[*12] As between petitioners and N & J Management, as of the end of December<br />
2003 N & J Management was treated as having no obligation to make additional<br />
premium payments on the six life insurance policies and the SDLIA arrangements<br />
were treated as having been released, ended, or terminated. Upon the above<br />
termination of the SDLIA arrangements, petitioners had sole rights to the remaining<br />
$745,463 balance in the cash surrender value of the life insurance policies. 8<br />
Apparently, no contemporaneous documentation exists (or was offered into<br />
evidence) relating to the December 2003 agreement between petitioners and<br />
N & J Management that ended or terminated the SDLIA arrangements. No written<br />
termination letter or agreement between petitioners and N & J Management with<br />
regard to the SDLIAs was offered into evidence. No written contract of any kind<br />
was offered into evidence relating to the above December 2003 agreement to end<br />
the SDLIAs. Further, no contemporaneous documentation refers to a sale by<br />
N & J Management to petitioners of “contract rights”.<br />
$745,463.<br />
8 Total cash surrender value of $877,432 less $131,969 received equals
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