Key legal question
Whether interest on loans used to finance single-premium life insurance policies is deductible or barred as tax avoidance
Extracted holding
The loans were unusually structured and, because the taxpayers failed to prove sufficient net assets to self-finance the premiums, the interest was not deductible.
Extracted reasoning
Applying the court's practice, tax avoidance is assumed where the loan debt for financing single-premium policies exceeds two thirds of net assets. Originary goodwill of the restaurant business was not assetizable and therefore could not improve the asset ratio; the higher valuation of the private property also did not remove the deficit. The financing was chosen essentially to obtain tax savings.