Turner v. Commissioner
United States Tax Court
Proceeds from the sale of a fractional interest in petitioner's rights to receive future commissions on accident and health insurance policies previously written by petitioner, an insurance broker, held to be taxable as ordinary income.
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies in petitioners’ income tax for the years 1956, 1957, and 1958 in the amounts of $1,204.28, $4,042.63, and $780.81, respectively.
All of the adjustments to income determined by respondent or asserted in pleadings have been disposed of by stipulation with the exception of the single issue presented here, which is: Does the sum of $14,603.45 received by petitioner under a contract of sale dated February 21, 1957, constitute ordinary income or capital gain?
FINDINGS OP PACT.
Some of the facts have been stipulated and they are found accordingly.
Pe…
2Cases cited5 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Helvering v. EubankSupreme Court of the United States · 1941
- Aitken v. CommissionerUnited States Tax Court · 1960
- Estate of Remington v. CommissionerUnited States Tax Court · 1947
3Cited by10 opinions
- Hodges v. CommissionerUnited States Tax Court · 1968
- Foxe v. CommissionerUnited States Tax Court · 1969
- Kathman v. CommissionerUnited States Tax Court · 1968
- Brown v. CommissionerUnited States Tax Court · 1969
- Hodges v. CommissionerUnited States Tax Court · 1968
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