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COTLOW v. COMMISSIONER OF INTERNAL REVENUE

No. 6, Docket 23399.

228 F.2d 186 (1955)

Lewis N. COTLOW, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided December 12, 1955.

Attorney(s) appearing for the Case

Abraham Kraditor, New York City, for petitioner.

H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Hilbert P. Zarky, Stanley P. Wagman, Attys., Washington, D. C., for Commissioner of Internal Revenue.

Before CLARK, Chief Judge, and LUMBARD and WATERMAN, Circuit Judges.

WATERMAN, Circuit Judge.

Petitioner is a life insurance agent who has been engaged since 1927 in purchasing from other insurance agents their rights to renewal commissions on life insurance policies. In 1948 he filed his individual return on the cash receipts and disbursements basis. He reported no income on account of assigned renewal commissions that year although he received during the year the total sum of $45,500.70 from assigned commissions on 1,648 policies...

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