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.
1Dissent
HaReoit, /.,
dissenting: The prevailing opinion treats the issue in a manner which is reminiscent of the evolution through the judicial process of concepts of the nature of taxable income and of what constitutes the realization of income. Indeed, the majority view seems to regard the Commissioner’s determination as one which serves to extend the frontier of the legal concept of income. Finally, in reaching the conclusion that no income was realized by petitioner, the majority has undertaken, I believe, to reduce the scope of the present legal concepts of income, and has disregarded well…
2Cases cited23 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Corliss v. BowersSupreme Court of the United States · 1930
- Blair v. CommissionerSupreme Court of the United States · 1937
- Helvering v. StuartSupreme Court of the United States · 1942
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