Leedy-Glover Realty & Ins. Co. v. Commissioner
United States Tax Court
1. Petitioner, a general insurance agency, wrote insurance policies on a large number of properties owned or controlled by Farm Security Administration. Under petitioner's contract with the insuring company its commissions on policies covering more than one year were placed in escrow and released to it each year ratably over the life of the policies. Petitioner was required under the contract to service the policies over their full terms.
Read the full summary
1. Petitioner, a general insurance agency, wrote insurance policies on a large number of properties owned or controlled by Farm Security Administration. Under petitioner's contract with the insuring company its commissions on policies covering more than one year were placed in escrow and released to it each year ratably over the life of the policies. Petitioner was required under the contract to service the policies over their full terms. Held, that the petitioner, reporting on an accrual basis, is taxable in each year on only that portion of the commissions which it became entitled to…
1Opinion of the Court
OPINION.
LeMire, Judge:(1) Accrual of commissions — Respondent’s position on this issue is that the petitioner, making its returns on an accrual basis, should have accrued as income in each of .the taxable years the entire amount of the commissions on insurance which it wrote for Houston in that year under the Government contract. The petitioner contends that it correctly reported only the commissions which, under its agreement with Houston, were payable to it within the taxable year, excluding the commissions held under the escrow agreement.
Under the Government contract, Houston was to…
2Cases cited7 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Brown v. HelveringSupreme Court of the United States · 1934
- American National Co. v. United StatesSupreme Court of the United States · 1927
- Your Health Club, Inc. v. CommissionerUnited States Tax Court · 1944
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Eli Lilly & Co. v. United StatesUnited States Court of Claims · 1967
- Kravetz v. United StatesDistrict Court, D. New Jersey · 1962
- Eli Lilly and Company v. The United StatesUnited States Court of Claims · 1967
- Chelsea Products, Inc. v. CommissionerUnited States Tax Court · 1951
- Chelsea Products, Inc. v. CommissionerUnited States Tax Court · 1951
2 more not listed; retrieve them via the Exa API.