Nicholas M. Blassie and Clara Blassie v. Commissioner of Internal Revenue

MATTHES, Circuit Judge.

This case is before the Court on petition to review the decision of the Tax Court, sustaining the Commissioner’s determination of deficiencies in Petitioners’ 1954, 1955 and 1956 individual income taxes. The opinion of the Tax Court is reported at 25 C.C.H. Tax Ct. Mem. 1291 (1967).

The sole issue is whether certain insurance commissions received by Petitioner, Nicholas M. Blassie, during the years in question in his capacity as an insurance broker constituted taxable income to him within the meaning of Section 61(a) of the Internal Revenue Code. 1 The facts, some of…