Davidson v. Commissioner
United States Board of Tax Appeals
Insurance commissions held on facts to have been earned by corporation's president, to whom they are taxable, and not by assignee corporation.
1Opinion of the Court
*583OPINION.
Oppee:
By his notice of deficiency for 1934 respondent included in petitioner’s income:
* * * the net income for 1934 of Estate Planning Corporation, after disallowance of a deduction claimed for bond interest in amount of $24,000.00. The income of Estate Planning Corporation appears to consist entirely of original commissions on life insurance policies and annuity insurance policies sold by you (and your sub-agents) under contracts in your name personally. In view of the nature of the income involved, it is held by this office to be taxable in your hands, subject to the ordinary and…
2Cases cited9 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Helvering v. EubankSupreme Court of the United States · 1941
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Hempt Bros., Inc. v. United StatesDistrict Court, M.D. Pennsylvania · 1973
- Patel v. CommissionerUnited States Tax Court · 1988
- Davidson v. CommissionerUnited States Board of Tax Appeals · 1941
- Hoile v. CommissionerUnited States Tax Court · 1945
- Nathan v. CommissionerUnited States Tax Court · 1943
1 more not listed; retrieve them via the Exa API.