- 27 - business included managing the Burke Property, collecting its liability against IML, and selling Lot 51. Petitioner also spent considerable time and money attempting to exchange the Burke Property for other real estate in a section 1031 transaction. Nevertheless, several of petitioner's claimed deductions deserve special attention. Several checks to the S.F. Commercial Club in both 1989 and 1990, a check to the Secretary of State of Colorado for $5 in 1990, and one to the Riverside County Clerk's Office for $67.80 in 1990 are unexplained, and are therefore disallowed. Petitioner claims that it maintained "key man insurance" on Byrne. Byrne testified that he had been an officer of the corporation, off and on, over the years. The corporate minutes indicate that he was also petitioner's vice president during 1989 and 1990. Petitioner was a 40-percent beneficiary under the policy. Under these facts, section 264(a) controls deductibility. It provides:Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011