American Sav. Bank v. Commissioner
United States Tax Court
Petitioners Harry and Carl Hagemann held all of the stock of Cedar Investment Co. Cedar, through outside agents, sold life insurance policies on the premises of two banks.
Read the full summary
Petitioners Harry and Carl Hagemann held all of the stock of Cedar Investment Co. Cedar, through outside agents, sold life insurance policies on the premises of two banks. In addition, Harry and Carl furnished management services to American Savings Bank which, in return, paid management fees to Cedar Investment Co. Held, the commissions on the insurance policy sales were earned by, and properly taxable to, Cedar Investment Co. Held, further, the fees paid for management services were earned by, and properly includable in the gross income of, Harry and Carl Hagemann. Held, further, the fees…
1Opinion of the Court
Fat, Judge:
Due to common issues, three cases have been consolidated for purposes of trial, briefing, and opinion. Eespondent asserts deficiencies in petitioners’ income taxes as follows:
Petitioners Deficiency 1963 1964 1965
American Savings Bank. Harry H. Hagemann and Shirley Hagemann. Oarl E. Hagemann and Dorothy Hagemann.-$1,620.00 $3,200.00 $1,750.61 3,218.82 3,252.72 3,173.05 3,191.69 3,279.17 3,162.90
The following questions must be decided by this Court:(1) Are the payments made by American Savings Bank to Cedar Investment Co. for management services actually performed by Harry and Carl…
2Cases cited13 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Lucas v. EarlSupreme Court of the United States · 1930
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
8 more not listed; retrieve them via the Exa API.
3Cited by62 opinions
- Vercio v. CommissionerUnited States Tax Court · 1980
- Wesenberg v. CommissionerUnited States Tax Court · 1978
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- Frederick H. Foglesong, Elizabeth C. Foglesong, and Frederick H. Foglesong Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Foglesong v. CommissionerUnited States Tax Court · 1981
57 more not listed; retrieve them via the Exa API.