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(a) General Rule--No deduction shall be allowed for--
(1) Premiums paid on any life insurance policy covering
the life of any officer or employee, or of any person
financially interested in any trade or business carried on
by the taxpayer, when the taxpayer is directly or indirectly
a beneficiary under such policy.
Since Byrne was an officer of petitioner, and since petitioner
was a beneficiary of the policy, petitioner may not deduct the
premium it paid on that policy. Merrimac Hat Corp. v.
Commissioner, 29 B.T.A. 690 (1934); Klinck v. Commissioner, a
Memorandum Opinion of this Court dated Dec. 31, 1952.
Respondent argues that petitioner was not entitled to deduct
automobile expenses due to lack of business purpose and
substantiation. Section 274(d) imposes stringent substantiation
requirements for travel, entertainment, gifts, and "listed
property (as defined in section 280F(d)(4))". Passenger
automobiles are listed property under section 280F(d)(4)(i).
Section 274(d) denies these deductions unless:
the taxpayer substantiates by adequate records or by
sufficient evidence corroborating the taxpayer's own
statement (A) the amount of such expense or other item, (B)
the time and place of the travel, entertainment, amusement,
recreation, or use of the facility or property, or the date
and description of the gift, (C) the business purpose of the
expense or other item, and (D) the business relationship to
the taxpayer of persons entertained, using the facility or
property, or receiving the gift. * * *
Under section 274(d), deductions for automobile expenses or
travel expenses may not be estimated. Instead the taxpayer must
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