Helvering v. Eubank

Eubank (plaintiff), a life-insurance agent, was entitled to future commissions on policy renewals, whose value depended on premiums later paid. In 1924 and 1928 he assigned the rights to two commissions to a trustee. The trustee received those commission payments in 1933. The Commissioner (defendant) determined the commissions should have been included in Eubank's 1933 income.

Whether an agent's earned commissions are taxable to him where he has assigned the right to receive the commission payments to an assignee.