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trust was lent to petitioner with a rate of return of 12 percent
per annum. Petitioner gave a mortgage on his residence and
condominium as security for the loans.
Petitioner claimed deductions for interest paid to the
trusts in the amounts of $30,000 in 1980 and $45,000 in 1981.
Priscilla Meier was an employee of petitioner or CDC.
George Hairston and David Johnston, the other trustees, were
attorneys. The funds in the trusts were invested in entities
controlled by petitioner. The trustees, acting in unison, were
independent and not subordinate or subservient to petitioner, the
grantor. Petitioner is entitled to the deductions for interest
paid to the J.J. Zand trusts for the years 1980 and 1981.
L. Claimed Deductions for Insurance Expenses
Petitioner is entitled to deduct insurance expenses of $825
for 1974 and $1,458 for 1975. He is not entitled to deduct
$1,365 for 1977 because the amount was not identified. In 1980
petitioner paid insurance premiums to McElroy-Minister in the
amount of $5,385. The policy with McElroy-Minister was a
liability policy covering various companies owned by him,
including CDC, CDC's four subsidiaries, and CTC. This amount is
deductible.
M. Claimed Deductions for Dues and Publications
In the notice of deficiency for 1978, 1979, and 1980, and
1981 respondent disallowed deductions claimed for dues and
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