Salyersville National Bank v. United States

CORNELIA G. KENNEDY, Circuit Judge.

Plaintiff Salyersville National Bank appeals from a summary judgment dismissing its claim for a refund of federal income taxes paid for the calendar years 1969,1970, and 1971. The Internal Revenue Service assessed taxpayer bank on the amount of commissions for credit life insurance purchased by the bank’s borrowers from the bank president, a licensed life insurance agent. Taxpayer bank did not require credit life insurance on every loan. However, for those on which it did and in those in stances where the borrower wished insurance, it was taxpayer bank’s…