Legal Opinion

William R. and Muriel G. Jackson v. Commissioner

United States Tax Court

Decided March 31, 1997No. 23558-94Unknown

1Opinion of the Court

108 T.C. No. 10

UNITED STATES TAX COURT WILLIAM R. AND MURIEL G. JACKSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23558-94. Filed March 31, 1997. P, a former insurance agent for State Farm Insurance Companies, received termination payments after his retirement on December 31, 1987, pursuant to the terms of an independent contractor Agent's Agreement. Held, the termination payments P received were not "derived" from a trade or business carried on by him as an insurance agent during 1990 and 1991. Therefore, such payments are not subject to self- employment tax…

2Cases cited24 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Nationwide Mutual Insurance v. DardenSupreme Court of the United States · 1992
  3. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  4. Arizona Governing Committee for Tax Deferred Annuity & Deferred Compensation Plans v. NorrisSupreme Court of the United States · 1983
  5. Simpson v. CommissionerUnited States Tax Court · 1975

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