Finley v. Commissioner
United States Tax Court
1. Petitioners received commissions in the taxable year with respect to accident and health group insurance policies; held, the commission income does not qualify under section 107(a) of the Internal Revenue Code of 1939 so that petitioners are not entitled to allocate the income ratably to several taxable years. 2. Respondent's disallowance of additional printing expenses sustained. 3. The failure of petitioners Smith to make or file a declaration of estimated tax for 1952,…
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1. Petitioners received commissions in the taxable year with respect to accident and health group insurance policies; held, the commission income does not qualify under section 107(a) of the Internal Revenue Code of 1939 so that petitioners are not entitled to allocate the income ratably to several taxable years. 2. Respondent's disallowance of additional printing expenses sustained. 3. The failure of petitioners Smith to make or file a declaration of estimated tax for 1952, held, not due to reasonable cause and respondent's determination of an addition to tax under section 294(d)(1)(A)…
1Opinion of the Court
Charles O. Finley, Shirley Finley, Petitioners, v. Commissioner of Internal Revenue, Respondent. Calvin L. Smith, Thelma F. Smith, Petitioners, v. Commissioner of Internal Revenue, Respondent
Finley v. Commissioner
Docket Nos. 58664, 58665
United States Tax Court
33 T.C. 753; 1960 U.S. Tax Ct. LEXIS 216;
January 29, 1960, Filed
Decisions will be entered under Rule 50.
1. Petitioners received commissions in the taxable year with respect to accident and health group insurance policies; held, the commission income does not qualify under section 107(a) of the Internal Revenue Code of 1939 so that…
2Cases cited7 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Commissioner v. AckerSupreme Court of the United States · 1959
- Commissioner of Internal Revenue v. Moline Properties, Inc.Court of Appeals for the Fifth Circuit · 1942
- Myers v. CommissionerUnited States Tax Court · 1948
- Gordon v. CommissionerUnited States Tax Court · 1948
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