James H. Shelton, Deceased, and Eve Shelton - Page 14

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          (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 payments                  






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