- 3 - agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE PANUTHOS, Chief Special Trial Judge: Respondent determined a deficiency in petitioners’ Federal income tax of $2,519 for 1997. All references to petitioner are to Warren L. Baker, Jr. After a concession by petitioners,3 the issue for decision is whether the termination payment received by petitioner upon retirement as an insurance agent of State Farm Insurance Cos. is taxable as capital gain or ordinary income. Background Some of the facts have been stipulated and are so found. The stipulated facts and the related exhibits are incorporated herein by this reference. At the time of filing the petition, petitioners resided in Fairview Heights, Illinois. I. Petitioner’s Agreement With State Farm a. General Petitioner began his relationship with State Farm Insurance Cos. (State Farm) on January 19, 1963. State Farm consisted of State Farm Mutual Automobile Insurance Co., State Farm Life 2(...continued) Court Rules of Practice and Procedure, unless otherwise indicated. 3 Petitioners concede that they failed to report dividend income of $919 from Magna Group, Inc.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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