Question juridique clé
Whether the interest on the loan financing single-premium life insurance could be deducted for direct federal tax 2002.
Solution extraite
No. The arrangement constituted tax avoidance, so the CHF 14,557 interest deduction was rightly refused.
Motifs extraits
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.