Local Finance Corp. v. Commissioner
United States Tax Court
Finance companies, licensed under the Indiana Small Loan Act and related Indiana statutes to make loans, made available to their debtors credit life insurance in connection with the loans. Such insurance was sold by an independent insurance company at a rate, standard in Indiana, which would allow for the payment of compensation to the party selling such insurance.
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Finance companies, licensed under the Indiana Small Loan Act and related Indiana statutes to make loans, made available to their debtors credit life insurance in connection with the loans. Such insurance was sold by an independent insurance company at a rate, standard in Indiana, which would allow for the payment of compensation to the party selling such insurance. The insurance was offered to the debtors on a voluntary basis by employees of the finance companies who had been designated as agents of the insurance company and who performed all the work necessary to sell and service the…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in the petitioners’ income tax as follows:
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The parties having agreed upon, one of the issues in docket Nos. 1693-65 and 1701-65 and the respondent having conceded error with respect to one of the issues in docket No. 1693-65, the issues remaining for decision are (1) whether, for the period January 1 to June 30, 1958, the respondent erred in allocating to the petitioners in docket Nos. 1693-65 through 1701-65, pursuant to sections 61 and 482 of the Internal Eevenue Code of 1954, a portion of the income reported by the…
Also in this document: Concurrence.
2Cases cited30 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. TowerSupreme Court of the United States · 1946
- Burnet v. HarmelSupreme Court of the United States · 1932
- Lyeth v. HoeySupreme Court of the United States · 1938
25 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Rubin v. CommissionerUnited States Tax Court · 1971
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- American Terrazzo Strip Co. v. CommissionerUnited States Tax Court · 1971
- Marc's Big Boy-Prospect, Inc. v. CommissionerUnited States Tax Court · 1969
- G.D. Searle & Co. v. CommissionerUnited States Tax Court · 1987
27 more not listed; retrieve them via the Exa API.