Legal Opinion

Olmstead, Inc. Life Agency v. Commissioner

United States Tax Court

Decided December 22, 1960No. Docket No. 78887Published

Petitioner was the exclusive general insurance agent for Iowa for an insurance corporation from 1929 through 1955. In 1955 the petitioner, responding to the insurance corporation's suggestion that the exclusive agency contract be terminated, executed a new agreement with the corporation under which the old contract was canceled and petitioner obtained the right to receive payments of $ 500 a month, beginning February 1, 1956, over a period of 180 months.

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Petitioner was the exclusive general insurance agent for Iowa for an insurance corporation from 1929 through 1955. In 1955 the petitioner, responding to the insurance corporation's suggestion that the exclusive agency contract be terminated, executed a new agreement with the corporation under which the old contract was canceled and petitioner obtained the right to receive payments of $ 500 a month, beginning February 1, 1956, over a period of 180 months. The insurance corporation based the total amount of consideration upon the present value, at the time of the new agreement, of the…

1Opinion of the Court

Olmsted Incorporated Life Agency, Petitioner, v. Commissioner of Internal Revenue, Respondent

Olmstead, Inc. Life Agency v. Commissioner

Docket No. 78887

United States Tax Court

35 T.C. 429; 1960 U.S. Tax Ct. LEXIS 8;

December 22, 1960, Filed

Decision will be entered for the petitioner.

Petitioner was the exclusive general insurance agent for Iowa for an insurance corporation from 1929 through 1955. In 1955 the petitioner, responding to the insurance corporation's suggestion that the exclusive agency contract be terminated, executed a new agreement with the corporation under which the old contract…

2Cases cited7 opinions

  1. Hort v. CommissionerSupreme Court of the United States · 1941
  2. Commissioner of Internal Revenue v. OatesCourt of Appeals for the Seventh Circuit · 1953
  3. Motor Products Corp. v. CommissionerUnited States Board of Tax Appeals · 1942
  4. City Bank Farmers Trust Co. v. HoeyDistrict Court, S.D. New York · 1942
  5. Olmstead, Inc. Life Agency v. CommissionerUnited States Tax Court · 1960

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