Commissioner of Internal Revenue v. Sol Minzer and Adele Minzer

JONES, Circuit Judge.

We are here concerned with the liability of Sol Minzer and Adele Minzer, his wife, for a federal income tax deficiency for the year 1954. The transactions from which the controversy stems were those of Sol Minzer and he will be referred to as the taxpayer. No issues of fact are presented.

In 1954 the taxpayer was an insurance agent or broker. During that year he procured or kept in force policies of insurance upon his life. As a representatative of the insurance companies which had issued the policies he became entitled to commissions on the policies to the same extent as…