Shaw v. Commissioner

Sterrett, J.,

concurring: I agree with the majority that the income at issue belongs and is taxable to the petitioners. With respect to the allocation issue I concur in the result, but would have reached that result by making a finding as to the value of the services rendered by Shaw Ford and American, allowing the value so found as an offsetting deduction against the premium income.

Raum, Scott, and Hall, JJ., agree with this concurring opinion.