American Credit Indemnity Co. v. State Tax Commission

By this proceeding, brought pursuant to article 78 of the CPLB, petitioner seeks review and annulment of determinations of the 'State Tax Commission which sustained assessments of additional franchise taxes for the years 1960-1964, inclusive.

The proceeding presents the question whether collection fees earned, pursuant to the terms of a contingent fee schedule embodied in a credit insurance policy, upon the collection by the insurer of accounts of the insured’s trade customers, are subject to the franchise tax specifically levied on "premiums ”. At the times of the assessments now before us,…