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C. I. R. v. OLMSTED INCORPORATED LIFE AGENCY

No. 16850.

304 F.2d 16 (1962)

COMMISSIONER OF INTERNAL REVENUE, Petitioner, v. OLMSTED INCORPORATED LIFE AGENCY, Respondent.

United States Court of Appeals Eighth Circuit.

June 4, 1962.

Attorney(s) appearing for the Case

Burt J. Abrams, Dept. of Justice, Washington, D. C., for petitioner, and Louis F. Oberdorfer, Asst. Atty. Gen., Washington, D. C., and Lee A. Jackson, Robert N. Anderson, Tax Div., Dept. of Justice, Washington, D. C., on the brief.

James P. Irish, Altoona, Iowa, for respondent and J. T. Haughey, Altoona, Iowa, on the brief.

Before VOGEL and RIDGE, Circuit Judges, and DEVITT, District Judge.

VOGEL, Circuit Judge.

The Commissioner of Internal Revenue, petitioner herein, seeks review and reversal of a decision by the Tax Court of the United States holding that Olmsted Incorporated Life Agency, respondent, did not realize taxable income upon the receipt by it in 1956 of a contract whereby it was to be paid monthly payments for a period of fifteen years in consideration for its surrender of all rights to future renewal commissions on previously written life...

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