Questione giuridica chiave
Whether interest on debt used to finance single-premium life insurance premiums is deductible
Decisione estratta
Interest is deductible only if the financing does not amount to tax avoidance; the new tax rules do not exclude scrutiny of the financing method.
Motivazione estratta
The court held that the taxation rules on single-premium insurance concern the tax treatment of the policy proceeds, not a special freedom to finance premiums by debt. Earlier anti-avoidance case law therefore remains relevant.