Legal Opinion

Custis v. Commissioner

United States Tax Court

Decided May 26, 1982No. Docket No. 5108-79UnpublishedCited by 1 opinion

Held, payments by petitioners (life insurance agents) to satisfy premium obligations of purchasers of life insurance policies may not be applied to reduce petitioners' gross commission income.

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Held, payments by petitioners (life insurance agents) to satisfy premium obligations of purchasers of life insurance policies may not be applied to reduce petitioners' gross commission income. Alex v. Commissioner,70 T.C. 322 (1978), affd. 628 F.2d 1222 (9th Cir. 1980), followed; however, such payments are deductible business expenses not paid in violation of a "generally enforced" state statute within the meaning of section 162(c)(2), I.R.C. 1954. Boucher v. Commissioner,77 T.C. 214 (1981), distinguished. Held further, substantiation of various business travel and entertainment expenses…

1Opinion of the Court

JOHN W. CUSTIS and ELEANOR H. CUSTIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Custis v. Commissioner

Docket No. 5108-79.

United States Tax Court

T.C. Memo 1982-296; 1982 Tax Ct. Memo LEXIS 454; 43 T.C.M. (CCH) 1511; T.C.M. (RIA) 82296;

May 26, 1982.

Held, payments by petitioners (life insurance agents) to satisfy premium obligations of purchasers of life insurance policies may not be applied to reduce petitioners' gross commission income. Alex v. Commissioner,70 T.C. 322 (1978), affd. 628 F.2d 1222 (9th Cir. 1980), followed; however, such payments are deductible business…

2Cases cited5 opinions

  1. Alex v. CommissionerUnited States Tax Court · 1978
  2. Schiffman v. CommissionerUnited States Tax Court · 1967
  3. James Alex and Betty Jean Alex v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  4. Boucher v. CommissionerUnited States Tax Court · 1981
  5. Frank F. And Romana M. Paal v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971

3Cited by1 opinion

  1. Roberson v. Internal Revenue Service (In re Roberson)United States Bankruptcy Court, M.D. Tennessee · 1994

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