- 3 - virtue of having made joint returns with her husband. Hereafter, we shall use the term “petitioner”, in the singular, to refer only to petitioner James J. Gales. Petitioner’s Engagement by International Marketing Agencies, Inc. During 1992 and 1993, petitioner was engaged as a national marketing director by International Marketing Agencies, Inc. (IMA), an insurance broker that sold health insurance to small businesses. Petitioner was responsible for IMA sales for the territory west of the Mississippi River. He would recruit agents to sell insurance in various territories he established. As well as selling insurance directly and receiving commissions from those sales, petitioner received an “override commission” on insurance sold by agents he recruited. Petitioner’s Agreement With IMA Petitioner’s engagement by IMA was governed by an agreement entered into between petitioner and IMA on February 15, 1989. As subsequently modified, that agreement (the agreement) was in effect in 1992 and 1993. The agreement provides that petitioner, as an independent contractor, is engaged for the purpose of soliciting and obtaining applications for insurance offered by insurance companies represented by IMA. Among the terms and conditions of the agreement are the following: COMMISSIONS WHILE UNDER CONTRACT 1) You [petitioner] will earn commissions, in the amount shown on the last page of this contract, on policies or certificates written by you as premiums are earned by the CO [thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011