Brown v. Commissioner
United States Tax Court
1. On March 30, 1956, petitioner entered into a contract with an insurance company wherein he was appointed an assistant director of agencies. The contract was amended on August 17, 1956. On January 11, 1957, petitioner and the insurance company entered into a contract wherein petitioner was appointed director of agencies.
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1. On March 30, 1956, petitioner entered into a contract with an insurance company wherein he was appointed an assistant director of agencies. The contract was amended on August 17, 1956. On January 11, 1957, petitioner and the insurance company entered into a contract wherein petitioner was appointed director of agencies. Under these contracts petitioner was to receive an overriding commission and a commission on renewals on all policies written by the agents under petitioner's supervision. On May 7, 1957, petitioner assigned all three of those contracts to an investment company in…
1Opinion of the Court
ArtjNDell, Judge:
Respondent determined a deficiency in income tax for the calendar year 1957 in the amount of $9,142.84.
Petitioners assign three errors, namely, (1) the reclassification from long-term capital gain to ordinary income of the gain realized on the sale of certain contracts; (2) the disallowance of $1,326.08 depreciation claimed on a 1956 automobile owned by petitioner Joseph W. Brown for 8 months in 1957 and used by him for business purposes; and (3) the disallowance of $343.94 expended by petitioner Joseph W. Brown to have the timber cruised on a tract of land which petitioner…
2Cases cited17 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
12 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Luna v. CommissionerUnited States Tax Court · 1964
- Kingsbury v. CommissionerUnited States Tax Court · 1976
- Flower v. CommissionerUnited States Tax Court · 1973
- Foxe v. CommissionerUnited States Tax Court · 1969
- Johnson v. CommissionerUnited States Tax Court · 1969
18 more not listed; retrieve them via the Exa API.