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Allstate for a percentage of their business expenses under a
formula known as the Office Expense Allowance (OEA). Expenses
reimbursed from the OEA included the following: (1) Support
staff; (2) sales location rent; (3) maintenance; (4) utilities;
and (5) telephones. Allstate paid petitioners' malpractice
insurance and State licensing fees during 1989, 1990, and 1991.
Allstate provided petitioners with some office furniture,
such as a desk, a side chair, a swivel chair, and a filing
cabinet. The office furniture provided by Allstate to
petitioners was not petitioners' property but remained the
property of Allstate. Allstate provided petitioners with
standard advertising signs, and they were also eligible to
participate in cooperative advertising through Allstate.
The success of petitioners' business was due mainly to the
personality, ability to sell, entrepreneurial spirit, hard work,
knowledge of the product, and desire to succeed on the part of
the Lozons, particularly Mrs. Lozon.
Since Allstate treated them as employees, petitioners were
allowed to participate in the Sears profit sharing fund.
Allstate made contributions of $89 and $139 on behalf of Mrs.
Lozon to the profit sharing fund for the years 1990 and 1991,
respectively.
Allstate also allowed petitioners to participate in its
pension plan. Allstate made contributions of $1,674 and $2,319
on behalf of Mr. Lozon into Allstate's pension plan for the years
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Last modified: May 25, 2011