Butts v. Comr. of IRS

These two appeals by the Commissioner of Internal Revenue, consolidated for oral argument, involve the appropriate tax treatment to be given to the arrangement of the taxpayers as agents selling life, automobile, fire, and other types of insurance for Allstate Insurance Company. The Commissioner of Internal Revenue contends they should be treated as employees. The taxpayers successfully contended in the United States Tax Court that they are independent contractors. We affirm.

These cases were heard and appealed separately from the decisions of different Tax Court judges, but the controlling…