132 / If a creditor pays premiums on a life insurance policy securing a non-business debt, can the creditor deduct the premium payments?
The deduction has been denied on the ground that the premium payments are a capital investment rather than expenses incurred “for the production or collection of income, or for the management, conservation and maintenance of property held for the production of income.”1
1. U.S. v. Mellinger, 228 F.2d 688 (5th Cir. 1956); Home News Publishing Co. v. Commissioner, TC Memo 1969-167; see also Blumenthal v. Commissioner, TC Memo 1963-269, aff’d, 14 AFTR 2d 5094 (4th Cir. 1964).
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