(Download) "Salyersville National Bank v. United States" by Sixth Circuit. United States Court Of Appeals # eBook PDF Kindle ePub Free
eBook details
- Title: Salyersville National Bank v. United States
- Author : Sixth Circuit. United States Court Of Appeals
- Release Date : January 30, 1980
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 68 KB
Description
Plaintiff Salyersville National Bank appeals from a summary judgment dismissing its claim for a refund of federal income taxes paid for the calendar years 1969, 1970, and 1971. The Internal Revenue Service assessed taxpayer bank on the amount of commissions for credit life insurance purchased by the banks borrowers from the bank president, a licensed life insurance agent. Taxpayer bank did not require credit life insurance on every loan. However, for those on which it did and in those instances where the borrower wished insurance, it was taxpayer banks practice to refer borrowers either to its president or to other agents or to ask for an existing policy as collateral. If insurance was purchased from the bank president, the bank would usually add the amount of the premium to the loan amount and credit the agencys account. At other times customers wrote checks directly to the president. It is the contention of the Commissioner of the Internal Revenue Service that the credit life insurance commissions paid by the banks borrowers to the banks president were actually income to the bank, which was then distributed to the president as dividends. The bank contends that the sums were never received by it and that its practices were the result of legitimate business needs and the requirements and demands of state law.
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