Legal Opinion

Tomlinson v. Commissioner

United States Tax Court

Decided June 29, 1972No. Docket Nos. 457-68, 458-68, 459-68, 460-68, 461-68, 462-68, 463-68, 3553-68Published

Petitioners, as partners in JBL&K, an insurance agency, purchased all of the stock of Schmeer Insurance Agency, Inc., a corporation engaged in the insurance brokerage business, primarily writing insurance in connection with a bank's consumer loan business, and the entire assets of Schmeer partnership, a general insurance agency.

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Petitioners, as partners in JBL&K, an insurance agency, purchased all of the stock of Schmeer Insurance Agency, Inc., a corporation engaged in the insurance brokerage business, primarily writing insurance in connection with a bank's consumer loan business, and the entire assets of Schmeer partnership, a general insurance agency. Subsequently, the two businesses were liquidated and JBL&K received all of their assets, including goodwill, insurance expiration lists, and a loss-experience record, and utilized them in the operation of its business. Held, the determination whether the insurance…

1Opinion of the Court

Robert G. Tomlinson, Surviving Husband, and Barbara S. Tomlinson, Deceased, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Tomlinson v. Commissioner

Docket Nos. 457-68, 458-68, 459-68, 460-68, 461-68, 462-68, 463-68, 3553-68

United States Tax Court

58 T.C. 570; 1972 U.S. Tax Ct. LEXIS 96;

June 29, 1972, Filed

Decisions will be entered for the respondent except in docket No. 458-68. Decision will be entered under Rule 50 in docket No. 458-68.

Petitioners, as partners in JBL&K, an insurance agency, purchased all of the stock of Schmeer Insurance Agency, Inc., a corporation…

2Cases cited20 opinions

  1. Michaels v. CommissionerUnited States Tax Court · 1949
  2. Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
  3. Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
  4. Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
  5. Boe v. CommissionerUnited States Tax Court · 1961

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