Kernrechtsfrage
Whether the interest on loans financing single-premium life insurance policies was deductible for direct federal tax 2002
Extrahierter Entscheid
No. The arrangement constituted tax avoidance, so the claimed loan-interest deduction was properly refused.
Extrahierte Begründung
The taxpayers used repeated loan-financed premium payments despite insufficient own assets, with loans also serving to finance subsequent policies and generating a substantial tax advantage. The court treated the structure as unusual and solely tax-driven.