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Golsen v. Commissioner : ウィキペディア英語版 | Golsen v. Commissioner
''Golsen v. Commissioner of Internal Revenue'', 54 T.C. 742 (1970), ''aff'd on other grounds'', 445 F.2d 985 (10th Cir. 1971), ''cert. denied'', 404 U.S. 940 (1971), is a case in which the United States Tax Court stated the principle that where the court of appeals to which an appeal would be made in a given case has already established a rule of precedent for a legal issue to be decided by the Tax Court, the Tax Court will follow the decision of that court of appeals.〔(【引用サイトリンク】title=Golsen v. Commissioner of Internal Revenue ) 〕 Under the rule (referred to as the Golsen Rule) articulated in the case, the Tax Court may render different decisions, based on identical situations, for taxpayers that are differentiated only by the geographical area in which the Tax Court case is decided. ==Background== Jack E. Golsen of Oklahoma City purchased what was purportedly a whole life insurance policy from Western Security Life Insurance Co. However, the tax court found that the loan structure of the policy was effectively a term life policy and subject to a 4% tax.
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