Legal Opinion

Sanborn v. Commissioner

United States Board of Tax Appeals

Decided April 8, 1930No. Docket No. 40963Published

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.

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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

  1. Sanborn v. CommissionerUnited States Board of Tax Appeals · 1930

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