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The document discusses a 1965 court case involving a tax dispute over life insurance proceeds received by a company for its deceased president. The company had taken out life insurance policies on its president and designated itself as the beneficiary. After his death, the company's board of directors granted part of the insurance proceeds to the deceased president's four minor children by converting it to company stock shares.

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Mark Oliver Evangelista
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32 views1 page

5 A

The document discusses a 1965 court case involving a tax dispute over life insurance proceeds received by a company for its deceased president. The company had taken out life insurance policies on its president and designated itself as the beneficiary. After his death, the company's board of directors granted part of the insurance proceeds to the deceased president's four minor children by converting it to company stock shares.

Uploaded by

Mark Oliver Evangelista
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as RTF, PDF, TXT or read online on Scribd
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II.

Donors Tax
Pirovano vs CIR

Pirovano vs. Commissioner of Internal Revenue (July 31, 1965)

Facts:
Sometime in the early part of 1941, De la Rama Steamship Co. insured the life of who
was then its President and General Manager until the time of his death, with various
Philippine and American insurance companies for a total sum of one million pesos,
designating itself as the beneficiary of the policies obtained by it. During the Japanese
occupation, in the latter part of 1944, Enrico Pirovano died.

After the liberation of the Philippines from the Japanese forces, the Board of Directors of
De la Rama Steamship Co. adopted a resolution dated July 10, 1946 granting and
setting aside, out of the proceeds expected to be collected on the insurance policies
taken on the life of said Enrico Pirovano, the sum of P400,000.00 for equal division
among the four (4) minor children of the deceased, said sum of money to be convertible
into 4,000 shares of stock of the Company, at par, or 1,000 shares for each child.
Shortly thereafter, the Company received the total sum of P643,000.00 as proceeds of
the said life insurance policies obtained from American insurers.

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