Ivan Andre Zaal - Page 2

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               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 agreements                







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