Key legal question
Whether the interest on the loan financing single-premium life insurance could be deducted for direct federal tax 2002.
Extracted holding
No. The arrangement constituted tax avoidance, so the CHF 14,557 interest deduction was rightly refused.
Extracted reasoning
The policy purchases were unusually structured and largely financed by loans despite insufficient net wealth; loan interest was repeatedly capitalized, reducing the insurance assets, and the scheme produced a tax saving.