- 2 - After concessions by petitioner, the issues for decision are (1) whether petitioner is liable for taxes on $113,081 in insurance renewal commissions that petitioner assigned to American Keystone Group, Inc., and (2) whether petitioner is liable for the substantial understatement penalty under section 6662(a) for 1994. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioner resided in Plano, Texas, at the time this petition was filed. Petitioner was an independent contractor at Pennsylvania Life Insurance Co. (Penn Life) from June 1974 through January 1994. Petitioner earned commissions on the insurance policies he sold on behalf of Penn Life. Petitioner and Penn Life contractually agreed that petitioner would receive commissions on certain policies petitioner personally sold while an independent contractor at Penn Life, when and if those policies renewed. Petitioner and Penn Life also contractually agreed that, after petitioner's employment with Penn Life was terminated, petitioner would continue to participate in the profits of Penn Life pursuant to a schedule to which petitioner and Penn Life agreed. During 1994, pursuant to the contractual agreementsPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011