Hodges v. Commissioner
United States Tax Court
Held: 1. Amount received by insurance agent as sales price of commissions on renewal premiums on 5-year fire and casualty insurance policies constitutes ordinary income. The portion of a composite price paid for an insurance business which is properly attributable to the purchase of the right to receive commissions on renewal premiums on 5-year policies determined from the evidence.
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Held: 1. Amount received by insurance agent as sales price of commissions on renewal premiums on 5-year fire and casualty insurance policies constitutes ordinary income. The portion of a composite price paid for an insurance business which is properly attributable to the purchase of the right to receive commissions on renewal premiums on 5-year policies determined from the evidence. Use of method used in notices of deficiency of computing portion of installment payment representing payment of portion of sales price attributable to right to receive commissions on renewal premiums on 5-year…
1Opinion of the Court
Scott, Judge:
Respondent determined deficiencies in the income taxes of the petitioners in the above-entitled cases for the years and in the amounts as follows:
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The issues for decision are:(1) Whether a portion of the payment received in each of the years 1962 and 1963 by Hugh H. and Ottie F. Hodges as proceeds from the sale of the Hodges Insurance Agency in the year 1961 represents an amount received from the sale of rights to renewal commissions under 5-year insurance policies in force at the date of the sale and as such is taxable to petitioners as ordinary income.(2) "Whether…
2Cases cited20 opinions
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Helvering v. EubankSupreme Court of the United States · 1941
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
- Boe v. CommissionerUnited States Tax Court · 1961
15 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Marsh & McLennan, Inc. v. CommissionerUnited States Tax Court · 1968
- International Life Ins. Co. v. CommissionerUnited States Tax Court · 1969
- Tomlinson v. CommissionerUnited States Tax Court · 1972
- Realty Loan Corp. v. CommissionerUnited States Tax Court · 1970
- Decker v. CommissionerUnited States Tax Court · 1987
9 more not listed; retrieve them via the Exa API.