Feder v. Comr., T.C. Memo. 2012-10

(petitioner received Form 1099-R reporting insurance policy distribution; petitioner believed that policy had been canceled many years earlier, but didn't provide evidence that cancellation done in accordance with policy terms and premiums continued to be paid in accordance with automatic loan provision of policy until loan balance equaled cash value of policy; policy lapsed and triggered constructive dividend equal to value exceeding petitioner's investment in contract). 

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