Legal Opinion
James Alex and Betty Jean Alex v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided September 22, 1980No. 78-3032PublishedCited by 19 opinions
1Opinion of the Court
CHOY, Circuit Judge:
Mr. Alex, a life insurance agent, noticed that by selling a large amount of insurance on behalf of his company he could receive in commissions, office allowances, and bonuses an amount greater than the insureds’ first-year premiums. To build his volume, he “sold” insurance in 1972 in violation of California law by reimbursing some insureds’ premium payments and by paying other insureds’ premiums himself. The Tax Court held that Alex could not deduct or exclude from his gross income the amounts he paid to and on behalf of the insureds. 70 T.C. 322 (1978) (8-7 decision),…
2Cases cited7 opinions
- Richard R. Sibla v. Commissioner of Internal Revenue, Robert E. Cooper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Max Sobel Wholesale Liquors v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Pittsburgh Milk Co. v. CommissionerUnited States Tax Court · 1956
- A. J. Ostheimer, 3rd, Ruth M. Ostheimer v. United StatesCourt of Appeals for the Third Circuit · 1959
- Alex v. CommissionerUnited States Tax Court · 1978
2 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Boucher v. CommissionerUnited States Tax Court · 1981
- Mickey L. Worden Virginia L. Worden v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1993
- Commissioner v. DunkinCourt of Appeals for the Ninth Circuit · 2007
- Wentz v. CommissionerUnited States Tax Court · 1995
- Edward W. Boucher and Gloria D. Boucher v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
14 more not listed; retrieve them via the Exa API.