Wisconsin Farmer Co. v. Commissioner
United States Tax Court
Petitioner was engaged in the publication of a farm paper during its base period, which extended from June 1, 1936, to May 31, 1940, inclusive. In addition to income from advertising, subscriptions, and other sources, petitioner realized profits from commissions earned on the sale of low cost accident insurance policies to subscribers.
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Petitioner was engaged in the publication of a farm paper during its base period, which extended from June 1, 1936, to May 31, 1940, inclusive. In addition to income from advertising, subscriptions, and other sources, petitioner realized profits from commissions earned on the sale of low cost accident insurance policies to subscribers. From January 10, 1930, to February 10, 1940, petitioner handled policies issued by the A insurance company under a contract with an insurance agent. In October, 1939, petitioner commenced direct negotiations with the B insurance company and on January 23, 1940,…
1Opinion of the Court
OPINION.
Arundell, Judge:
In this proceeding, petitioner contests the respondent’s disallowance of its claim for relief under section 722 (b) (4) and (b) (5) of the Internal Revenue Code.5 Petitioner contends that the substitution of a different contract under which it sold accident policies to its subscribers from and after February 10,1940, constituted a change in its business operations equivalent to a “change in the character of the business” under section 722 (b) (4), or was a factor which resulted in an inadequate standard of normal earnings during the base period within the meaning of…
2Cases cited6 opinions
- Lamar Creamery Co. v. CommissionerUnited States Tax Court · 1947
- East Texas Motor Freight Lines v. CommissionerUnited States Tax Court · 1946
- 7-Up Ft. Worth Co. v. CommissionerUnited States Tax Court · 1947
- Irwin B. Schwabe Co. v. CommissionerUnited States Tax Court · 1949
- Stonhard Co. v. CommissionerUnited States Tax Court · 1949
1 more not listed; retrieve them via the Exa API.
3Cited by83 opinions
- Granite Constr. Co. v. CommissionerUnited States Tax Court · 1952
- Farmers Creamery Co. v. CommissionerUnited States Tax Court · 1952
- Ray Campbell, Wise & Wright, Inc. v. CommissionerUnited States Tax Court · 1950
- Triangle Raincoat Co. v. CommissionerUnited States Tax Court · 1952
- General Metalware Co. v. CommissionerUnited States Tax Court · 1951
78 more not listed; retrieve them via the Exa API.