Professional Ins. Agents v. Commissioner
United States Tax Court
Petitioner is a professional association of Michigan independent insurance agents and is exempt from tax as a business league under sec. 501(c)(6), I.R.C. 1954. During the taxable years in issue, petitioner performed various promotional and administrative services in connection with certain malpractice, health, disability, and life insurance programs underwritten by private insurance companies and made available to petitioner's members.
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Petitioner is a professional association of Michigan independent insurance agents and is exempt from tax as a business league under sec. 501(c)(6), I.R.C. 1954. During the taxable years in issue, petitioner performed various promotional and administrative services in connection with certain malpractice, health, disability, and life insurance programs underwritten by private insurance companies and made available to petitioner's members. For its efforts, petitioner received fees based on varying percentages of the premiums paid by participating members. In March 1975, petitioner received an…
1Opinion of the Court
Dawson, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Deficiency TYE Sept. 30-
$17,200.57 1974
41,692.72 1975
24,134.69 1976
After concessions, the issues for decision are whether the following amounts received by petitioner, a business league of insurance agents exempt from taxation pursuant to section 501(c)(6),1 constituted unrelated business taxable income under section 512:(1) Fees received for performing various promotional and administrative services in connection with certain malpractice, health, disability, and life insurance programs which…
2Cases cited15 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- International Trading Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1960
- Disabled American Veterans v. United StatesUnited States Court of Claims · 1981
- Hope v. CommissionerUnited States Tax Court · 1971
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3Cited by42 opinions
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- Carolinas Farm & Power Equipment Dealers Association, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1983
- Nordberg v. CommissionerUnited States Tax Court · 1982
- National Water Well Ass'n v. CommissionerUnited States Tax Court · 1989
- Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1989
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