Albright v. Commissioner
United States Board of Tax Appeals
A life insurance agent who advances the first premiums due upon policies he writes for customers, believing and expecting that the money will be repaid to him, held not entitled to deduct as "ordinary and necessary expenses," the amounts so paid.
1Opinion of the Court
*1230OPINION.
MaRqtjette :
The petitioner contends that his payment, in the first instance, of the premiums on the life insurance policies which he wrote for Stratton was an “ ordinary and necessary expense paid * * * during the taxable year in carrying on ” his trade or business; and that it is, therefore, deductible from gross income under section 214 (a) (1) of the 1921 Revenue Act.
In our opinion, the amount of premiums paid by the petitioner is not deductible as a business expense. We have no doubt that advancement of premiums for new policyholders was an ordinary procedure, frequently followed…
2Cited by11 opinions
- Canelo v. CommissionerUnited States Tax Court · 1969
- Reginald G. Hearn and Mary L. Hearn, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Burnett v. CommissionerUnited States Tax Court · 1964
- Boccardo v. United StatesUnited States Court of Claims · 1987
- Rca Communications, Inc. v. United StatesUnited States Court of Claims · 1960
6 more not listed; retrieve them via the Exa API.