-3- income and Schedule A employee business expenses as Schedule C items. Issue 1. Retirement Plan Contributions The first issue for decision is whether petitioners are entitled to a deduction for contributions allegedly made by or on behalf of petitioner to a retirement plan. Cal-American Petitioner was involved in the formation of Cal-American Insurance Company (Cal-American), a property and casualty insurance company, and was its president from September 1984 to March 1989. Prior to Cal-American’s formation, petitioner was the deputy insurance commissioner for the State of California. Cal-American was acquired in 1987 by Westech Insurance Network, Inc. (Westech), which also owned Bancsure Insurance Services, Inc. (Bancsure). Although president of Cal-American, in actuality petitioner was an employee of Westech. And, from the time Cal-American was acquired by Westech until March 1989, petitioner’s salary as well as reimbursement for his expenses were paid by Bancsure, which issued a Form 1099-Misc. and Form W-2 to petitioner for 1989. The Form 1099-Misc. reflected nonemployee compensation in the amount of $32,422.56. The Form W-2 reflected wages paid to petitioner in the amount of $62,500. The $62,500 was composed of salary payments for January and February, plus a severance payment. ArrowheadPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011