The Tax Court decided several years ago that increases in the value of endowment policies under certain

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The Tax Court decided several years ago that increases in the value of endowment policies under certain circumstances are income. The court drew a distinction between endowment policies and other assets such as stock whose appreciation reflects price changes over time. The gain in value of an endowment policy results from the annual addition to the investment fund of the earnings on the investments, and the gain is not directly related to price changes.

Comment on the distinction.

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