- 5 - On its amended 1988 and 1989 U.S. Life Insurance Company Income Tax Returns, Forms 1120L, AFLIC respectively reported $3,000,498 and $2,958,091 in gross premiums and respectively took deductions for commissions paid in the amounts of $1,366,543 and $1,360,371.4 Respondent sent petitioner a notice of deficiency dated October 28, 1992, which included increases to petitioner’s gross income in the amounts of $1,083,197 and $1,140,414, for the years 1988 and 1989, respectively, to clearly reflect commission income from the sale of credit insurance during 1988 and 1989. On or about September 23, 1985, Matheney Ford, Inc. (Matheney Ford), executed a loan agreement and promissory note (the loan agreement) whereby AFLIC and AFIC agreed to and did lend Matheney Ford $225,000. The president of Matheney Ford was George O. Cooper, Jr. (Cooper). AFIC and AFLIC were granted a security interest in Matheney Ford’s used cars and certain accounts. Cooper executed a guaranty for Matheney Ford’s debt. As security for his guaranty, Cooper and his wife executed a deed of trust on their residence in favor of AFLIC and AFIC. The deed of trust was subordinate to a first deed of trust held by Trustmark National Bank (Trustmark) as security for promissory 4 AFLIC’s commission deductions include the commission income allocated to petitioner under sec. 482. The commission deductions were claimed on the amended return to preserve the deduction in the event respondent prevailed on the proposed sec. 482 adjustment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011