Cotlow v. Commissioner
United States Tax Court
1. Held, renewal insurance commissions received by petitioner in the taxable year by reason of bona fide assignments for value from various insurance agents constituted taxable income to petitioner to the extent which the aggregate amount thereof exceeded the total consideration paid by him for such assignments. 2. Held, the income so realized by petitioner is taxable as ordinary income.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The sole issue involves the proper treatment for tax purposes to be accorded the receipt of insurance renewal premiums in the taxable year by petitioner as the assignee for valuable consideration of various insurance agents. Respondent has determined and here maintains that such receipts represent ordinary income to petitioner under section 22 (a), Internal Revenue Code, to the extent they exceed the aggregate of the amounts paid to the assignors by petitioner in consideration of the assignments.
It is petitioner’s position that he realized no taxable income from the…
2Cases cited3 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Blair v. CommissionerSupreme Court of the United States · 1937
- Helvering v. EubankSupreme Court of the United States · 1941
3Cited by21 opinions
- Latendresse v. CommissionerUnited States Tax Court · 1956
- Lewis N. Cotlow v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1955
- Hodges v. CommissionerUnited States Tax Court · 1968
- West v. CommissionerUnited States Tax Court · 1962
- Hall v. CommissionerUnited States Tax Court · 1968
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