BOYLE, FLAGG & SEAMAN, INC. v. COMMISSIONER

Docket No. 50720.

25 T.C. 43 (1955)

BOYLE, FLAGG & SEAMAN, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 18, 1955.


Attorney(s) appearing for the Case

Gerard A. Serritella, Esq., for the petitioner.

Andrew Kopperud, Jr., Esq., for the respondent.


The respondent determined deficiencies in the income tax of petitioner in the amount of $11,821.77 for the year 1948 and $20,675.89 for the year 1949.

The questions are:

1. Is petitioner entitled to exclude from its gross income that portion of insurance commissions actually received by it which was equal to amounts that it subsequently paid to unlicensed automobile dealers and others for soliciting insurance?

2. If such amounts are not excludible...

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