Question juridique clé
Whether the interest on loans financing single-premium life insurance premiums is deductible for federal income tax and cantonal taxes.
Solution extraite
The interest was not deductible because the financing structure constituted tax avoidance.
Motifs extraits
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.