Ranz v. Commissioner
United States Tax Court
Petitioner, a professional engineer and sales representative of machine tool manufacturers in an area including Cincinnati, Ohio, entered into an informal contract with the Rehnberg-Jacobson Manufacturing Co. in March 1951, to sell machine tools manufactured by it, on a commission basis.
Read the full summary
Petitioner, a professional engineer and sales representative of machine tool manufacturers in an area including Cincinnati, Ohio, entered into an informal contract with the Rehnberg-Jacobson Manufacturing Co. in March 1951, to sell machine tools manufactured by it, on a commission basis. Shortly thereafter he contacted and began negotiations with the Automatic Transmission Division of the Ford Motor Company, located in Cincinnati, to sell it machine tools manufactured by Rehnberg for use in manufacturing the automatic transmission assembly which it was then developing. As a result of his…
1Opinion of the Court
Bruce, Judge:
Respondent has determined deficiencies in petitioner’s income tax as follows:
Tear Deficiency
1952_ $114.00
1953_ 69.71
1954_3,571.58
At the hearing petitioner conceded certain issues with respect to respondent’s disallowance of club initiation fees in the amounts of $375 and $120 claimed by petitioner as business expense deductions for the years 1952 and 1953. The sole issue for decision is whether the provisions of section 1301 of the Internal Revenue Code of 1954 are applicable to commissions in the amount of $35,299.69 received by petitioner in 1954.
FINDINGS OF FACT.
Petitioner is…
2Cases cited7 opinions
- Smart v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Lum v. CommissionerUnited States Tax Court · 1949
- Nast v. CommissionerUnited States Tax Court · 1946
- Slough v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1945
- Myers v. CommissionerUnited States Tax Court · 1948
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- H. G. And Frances Kellam Hendricks v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
- Maurice J. Breen and Alyce J. Breen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Ralph B. Wattley and Josephine R. Wattley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Frank Stephen Ranz v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1960
- Finley v. CommissionerUnited States Tax Court · 1960
4 more not listed; retrieve them via the Exa API.