Legal Opinion

Sebring v. Commissioner

United States Tax Court

Decided August 8, 1989No. Docket No. 32875-87Published

P, a bail bondsman, is the agent of the surety that issues each bailbond. The surety is liable to the State for costs and forfeitures experienced if a bonded defendant fails to appear in court. P is required to indemnify the surety for such costs and forfeitures. As security for his promise to indemnify, P must pay to the surety a percentage of the fees collected on execution of the bond. The surety manages the funds collected and acts as trustee of the funds.

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P, a bail bondsman, is the agent of the surety that issues each bailbond. The surety is liable to the State for costs and forfeitures experienced if a bonded defendant fails to appear in court. P is required to indemnify the surety for such costs and forfeitures. As security for his promise to indemnify, P must pay to the surety a percentage of the fees collected on execution of the bond. The surety manages the funds collected and acts as trustee of the funds. The funds may be used solely for the purpose of satisfying P's promise to indemnify the surety. P is entitled to receive back the…

1Opinion of the Court

Leslie W. Sebring and Nanci M. Sebring, Petitioners v. Commissioner of Internal Revenue, Respondent

Sebring v. Commissioner

Docket No. 32875-87

United States Tax Court

93 T.C. 220; 1989 U.S. Tax Ct. LEXIS 116; 93 T.C. No. 20;

August 8, 1989August 8, 1989, Filed

Decision will be entered for the respondent.

P, a bail bondsman, is the agent of the surety that issues each bailbond. The surety is liable to the State for costs and forfeitures experienced if a bonded defendant fails to appear in court. P is required to indemnify the surety for such costs and forfeitures. As security for his promise to…

2Cases cited19 opinions

  1. Hradesky v. CommissionerUnited States Tax Court · 1975
  2. Frank J. Hradesky v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1976
  3. World Airways, Inc. v. CommissionerUnited States Tax Court · 1974
  4. Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
  5. World Airways, Inc., and World Air Center, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1977

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