T.C. Memo. 1999-27
UNITED STATES TAX COURT
JAMES J. AND SANDRA A. GALES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4345-97. Filed February 1, 1999.
P received advance commissions on insurance
written by him. The advance commissions were repayable
on demand, and bore interest, and repayment was secured
by earned commissions. Such advance commissions were
shown as income on Forms 1099-MISC, Miscellaneous
Income, received by P. Held, Ps have proven the amount
of advance commissions. Held, further, the advance
commissions were received as loans and are not gross
income.
S. Thomas Ullman, for petitioners.
Thomas E. Ritter, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated December 6,
1996, respondent determined deficiencies in petitioners' Federal
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