- 14 - (1946). Petitioners have not convinced us that the pickup truck was otherwise used for business purposes during the year in issue. Accordingly, petitioners are not entitled to an additional deduction for automobile expenses. D. Insurance Expense Deduction On the Schedule C, petitioners claimed a $1,475 insurance expense deduction that was disallowed in the notice of deficiency. A portion of the deduction relates to the cost of insurance on petitioner's pickup truck. According to petitioner, the balance of the deduction relates to some form of liability insurance that petitioner was required to have in connection with the rental of the airport space that he used as his classroom. As indicated above, section 162 allows a deduction for ordinary and necessary expenses incurred in connection with a trade or business. Sec. 162(a). No deduction under section 162 is allowed for insurance with respect to property that is not used in a trade or business. Edgar v. Commissioner, T.C. Memo. 1979- 524; Lenington v. Commissioner, T.C. Memo. 1966-264. Petitioner has not presented the Court with any evidence to show what type of insurance policy he acquired in connection with the rental of the classroom, nor did he explain why such coverage was necessary. As previously discussed, petitioners have failed to prove that petitioner's pickup truck was used in connection with his Schedule C business. Accordingly, we find that paymentsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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