- 14 -
home loan portfolio produced $87,974 interest for 1995 and
$89,357 interest for 1996.
3. Insurance Underwriting
Before petitioner could install a mobile home on a buyer’s
location, the buyer had to insure the mobile home. As a licensed
fire and casualty insurance agent, Jack wrote insurance policies
for 60 percent of petitioner’s sales. These policies were then
attached to their corresponding notes, which were sold to banks.
The commissions earned from the insurance sales went to
petitioner. Petitioner reported “Part. & Insurance Income” of
$58,019 and $44,566, respectively, on its 1995 and 1996 tax
returns.
G. Conclusions
Table 4 sets forth the parties’ and the Court’s positions
with respect to claimed compensation payments by petitioner to
Jack for the years in issue. Petitioner contends that all of the
amounts paid meet the requirements for deductibility, and that
greater payments, unspecified in amount, also would be
deductible. Respondent’s determinations and contentions, and the
Court’s redeterminations, are in terms of the maximum amounts
that meet the requirements for deductibility.
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011