Minzer v. Commissioner
United States Tax Court
Held, so-called commissions with respect to life insurance written by an insurance broker on his own life represent merely a reduction in the cost of such insurance to him and do not constitute the realization of taxable income by him within the meaning of the revenue laws.
1Opinion of the Court
OPINION.
Rattm, Judge:
The Commissioner determined a deficiency in income tax in the amount of $213.90 for the calendar year 1954. An issue raised by an amendment to respondent’s answer has been settled by agreement. The facts in relation to the original determination were fully stipulated.
Petitioners, husband and wife, residing in Dallas, Texas, filed a joint income tax return for 1954; the matter in controversy relates to the husband, who will hereinafter be referred to as petitioner.
Petitioner was an insurance broker. He was engaged in 1954 in the business of soliciting and writing life…
Also in this document: Concurrence.
2Cases cited3 opinions
- M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
- Silverman v. McGinnesCourt of Appeals for the Third Circuit · 1958
- Ostheimer v. United StatesDistrict Court, E.D. Pennsylvania · 1958
3Cited by16 opinions
- Mensik v. CommissionerUnited States Tax Court · 1962
- Alabama-Georgia Syrup Co. v. CommissionerUnited States Tax Court · 1961
- Commissioner of Internal Revenue v. Sol Minzer and Adele MinzerCourt of Appeals for the Fifth Circuit · 1960
- Commissioner of Internal Revenue v. Kenneth W. Daehler and Mary Daehler, His WifeCourt of Appeals for the Fifth Circuit · 1960
- Bailey v. CommissionerUnited States Tax Court · 1964
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