Marcus Wayne and Judity Caroline Ramsey - Page 3

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          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.                             
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