A taxpayer, who became an insurance broker after the revocation of his contract as an insurance agent, is proceeding with the clients of his former agency as part of his new business. He is ordered to pay compensation for unfair competition from the insurance company which employed him.
Are these allowances deductible from the taxpayer’s total income?
No, answers the Bordeaux Administrative Court of Appeal: these practices have exposed the taxpayer to an abnormal risk.
Consequently, the losses incurred after this conviction do not have the character of expenses necessitated by the exercise of his profession.