274 / Are premiums deductible when paid by a partnership or by a partner for insurance on the life of a copartner?

No.

This is true regardless of who is named beneficiary. Premiums paid for any life insurance, or endowment or annuity contract, are not deductible if a taxpayer is directly or indirectly a beneficiary under the policy or contract.¹ Whether insurance is purchased as a key person policy or to finance the purchase of an insured’s partnership interest, the premium paying partner will benefit from the policy.² For insurance purchased by a partnership on the life of an employee who is not a partner, see Q 262 and Q 263.

1.     IRC § 264(a)(1).