Sanborn v. Commissioner
United States Board of Tax Appeals
An insurance agent's contract with his company allowed him all commissions on policies written in territory assigned him, but required him to organize such territory, write insurance, employ, train and supervise the work of subagents therein, whose commissions were paid by him, all of which he did.
Read the full summary
An insurance agent's contract with his company allowed him all commissions on policies written in territory assigned him, but required him to organize such territory, write insurance, employ, train and supervise the work of subagents therein, whose commissions were paid by him, all of which he did. His net commissions were in each taxable year in excess of $20,000. Held, petitioner was entitled to claim in each taxable year $20,000 as earned net income for personal services actually rendered.
1Opinion of the Court
FRED C. SANBORN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Sanborn v. Commissioner
Docket No. 40963.
United States Board of Tax Appeals
19 B.T.A. 495; 1930 BTA LEXIS 2379;
April 8, 1930, Promulgated
An insurance agent's contract with his company allowed him all commissions on policies written in territory assigned him, but required him to organize such territory, write insurance, employ, train and supervise the work of subagents therein, whose commissions were paid by him, all of which he did. His net commissions were in each taxable year in excess of $20,000. Held, petitioner…
2Cases cited1 opinion
- Sanborn v. CommissionerUnited States Board of Tax Appeals · 1930