Boyle, Flagg & Seaman, Inc. v. Commissioner
United States Tax Court
1. Gross premiums received by petitioner from automobile dealers under oral agreements wherein petitioner agreed to pay dealers a percentage of its commission in consideration for their services in soliciting and sending to it applications for personal liability and property damage insurance held to be includible in gross income. 2. Payments prohibited by the insurance laws of the State of Illinois, made by petitioner to nonlicensed automobile dealers and others for…
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1. Gross premiums received by petitioner from automobile dealers under oral agreements wherein petitioner agreed to pay dealers a percentage of its commission in consideration for their services in soliciting and sending to it applications for personal liability and property damage insurance held to be includible in gross income. 2. Payments prohibited by the insurance laws of the State of Illinois, made by petitioner to nonlicensed automobile dealers and others for soliciting insurance for it, held not to be deductible as ordinary and necessary business expenses under section 23 (a) (1) (A)…
1Opinion of the Court
Boyle, Flagg & Seaman, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Boyle, Flagg & Seaman, Inc. v. Commissioner
Docket No. 50720
United States Tax Court
25 T.C. 43; 1955 U.S. Tax Ct. LEXIS 77;
October 18, 1955, Filed
Decision will be entered under Rule 50.
1. Gross premiums received by petitioner from automobile dealers under oral agreements wherein petitioner agreed to pay dealers a percentage of its commission in consideration for their services in soliciting and sending to it applications for personal liability and property damage insurance held to be includible in gross…
2Cases cited26 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Lilly v. CommissionerSupreme Court of the United States · 1952
- Bowles v. Farmers Nat. Bank of Lebanon, Ky.Court of Appeals for the Sixth Circuit · 1945
- Fuller v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Jerry Rossman Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1949
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