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
Hugh H. Hodges and Ottie F. Hodges, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Hodges v. Commissioner
Docket Nos. 1669-66, 1670-66, 1681-66, 1682-66
United States Tax Court
50 T.C. 428; 1968 U.S. Tax Ct. LEXIS 116;
June 4, 1968, Filed
Decisions will be entered under Rule 50.
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…
2Cases cited21 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
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