Neff v. Comr., T.C. Memo. 2012-244

(corporate executives entered into split-dollar life insurance policies with company in 2002; policies terminated in 2003 upon change in IRS tables at time when company had paid $842,345 in premiums and policies turned over to executives; executives paid back present value of premium recovery value based on their life expectancies resulting in payment of $131,969; IRS asserted that full $842,345 should have been reported in income; court agreed with IRS essentially viewing matter as debt forgiveness  - executives wealth increased by full amount of additional premiums paid rather than just present value of premium recovery).