) The cases of Matter of American Credit Ind. Co. of N.Y. v. State Tax Comm. of State of N.Y. ( 31 A.D.2d 27) and Matter of Consolidated Edison Co. of N.Y. v. State Tax Comm. of State of N Y ( 24 N.Y.2d 114) relied upon by petitioner are clearly distinguishable, and do not support petitioner's contentions. In the American Credit Ind. Co. case the question involved was whether collection fees earned, pursuant to the terms of a contingent fee schedule embodied in a credit insurance policy, upon the collection by the insurer of accounts of the insured's trade customers, were subject to the franchise tax specifically levied on "premiums".