Menin v. Tully
The petitioner, an estate planner and life insurance agent, sought to review a State Tax Commission determination sustaining a deficiency assessment for unincorporated business taxes for various years between 1964 and 1974. The respondent concluded that the petitioner was an independent contractor rather than an employee. Petitioner worked under an agent’s career contract for New England Life Insurance Company and its general agent, but also sold insurance for other principals and operated with considerable independence, including maintaining his own office and incurring substantial business expenses. The court affirmed the determination, finding substantial evidence to support the conclusion that the petitioner was an independent contractor and therefore subject to the unincorporated business tax.