Bay Counties Title Guaranty Co. v. Commissioner

OPINION'.

HaeRON, Judge:

The issue relates to the matter of the proper treatment for tax purposes of an expense which petitioner incurs and pays in cash each year to real estate brokers, chiefly, for preliminary title reports and copies of noncurrent title insurance policies which have been prepared and used previously by others in the same business. For convenience such material is described hereinafter, collectively, as starter reports.

It is understood that for the most part each of the starter reports acquired deals with the status of the title to an individual and different piece of real…