Key legal question
Whether the interest on loans financing single-premium life insurance premiums is deductible for federal income tax and cantonal taxes.
Extracted holding
The interest was not deductible because the financing structure constituted tax avoidance.
Extracted reasoning
The courts found an unusual and economically inappropriate arrangement: repeated borrowing to fund premiums, low net wealth compared with premiums paid, and actual tax savings. The taxpayers therefore had to be taxed as if they had chosen the economically appropriate financing.