Legal Opinion

Baker v. Comm'r

United States Tax Court

Decided May 29, 2002No. 599-00Published

P (husband) entered into "agents agreements" (agreement) with State Farm Insurance Cos. (State Farm) wherein P agreed to write insurance policies exclusively for State Farm. The agreement provided that all property including information about policy holders belonged to State Farm. P's compensation was based on a percentage of net premiums. The agreement also contained detailed provisions for termination.

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P (husband) entered into "agents agreements" (agreement) with State Farm Insurance Cos. (State Farm) wherein P agreed to write insurance policies exclusively for State Farm. The agreement provided that all property including information about policy holders belonged to State Farm. P's compensation was based on a percentage of net premiums. The agreement also contained detailed provisions for termination. P was entitled to a termination payment based on the percentage of policies that either (1) remained in force after termination or (2) were in force for the 12 months preceding termination. P…

1Opinion of the Court

WARREN L. BAKER, JR. AND DORRIS J. BAKER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Baker v. Comm'r

No. 599-00

United States Tax Court

118 T.C. 452; 2002 U.S. Tax Ct. LEXIS 28; 118 T.C. No. 28;

May 29, 2002, Filed

Decision will be entered for respondent.

P (husband) entered into "agents agreements"

(agreement) with State Farm Insurance Cos. (State Farm) wherein

P agreed to write insurance policies exclusively for State Farm.

The agreement provided that all property including information

about policy holders belonged to State Farm. P's compensation

was based on a percentage of net…

2Cases cited20 opinions

  1. Commissioner v. BrownSupreme Court of the United States · 1965
  2. Hort v. CommissionerSupreme Court of the United States · 1941
  3. Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
  4. Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
  5. Levy v. CommissionerUnited States Tax Court · 1988

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