- 18 - bears the notation "Insurance". However, petitioner did not offer or provide health insurance to any other employee. Moreover, petitioner has provided no evidence that a check written to Maynard & McDonald substantiates an employee health insurance expense. We find that petitioner has failed to establish that these expenditures were incurred primarily for business reasons. Henry v. Commissioner, supra; Larrabee v. Commissioner, supra. Petitioner claimed a deduction for a check in the amount of $200 payable to Renata. Petitioner contends that the check represented reimbursement of mileage incurred by her employee. The check bears the notation "Mileage 11/29-12/15/89". However, it was not petitioner's practice to reimburse employees for mileage in a separate check. Instead, employees reported mileage on their biweekly time sheets and were reimbursed in their regular pay checks. This practice applied to Renata as well. Petitioner has provided no credible evidence to explain why this particular reimbursement was handled out of the ordinary course. Accordingly, we uphold respondent's disallowance of this deduction. Petitioner claimed a deduction for payments of $1,100 and $500 to Florin Road Nissan as a downpayment for a car for Renata. Petitioner testified that it was necessary for Renata to travel as part of her job responsibilities. Petitioner further testified that after Renata had been working for a few weeks, her car failed, and petitioner agreed to help Renata purchase a new car to facilitate her business-related travel. Petitioner handled thePage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011