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c. Insurance. Petitioners claim insurance expense for
their business liability insurance and for their vehicle
insurance. As to the latter, petitioners must still comply with
the provisions of section 274(d) as described above, and having
failed to do so, cannot deduct any amount for vehicle insurance.
Moreover, the record does not contain any information as to
vehicle insurance costs.
With regard to the business liability insurance, petitioners
contend that they carried a large policy with Ohio Casualty,
which required a substantial down payment and monthly payments of
$147.99. The record contains one check to the insurance broker
stated to be a monthly payment thereof. The record was left open
in this case for 60 days for petitioners to contact their
insurance company for documentary verification of their claim.
Nothing was received from petitioners in this regard.3 From this
record, we are satisfied that petitioners paid the regular
monthly premiums for the business insurance, but there is no
evidence of the existence, amount, or date of payment of the
alleged “substantial downpayment.” Accordingly, we hold that
3 Indeed, as will be noted, the record was left open for
several reasons, all to no avail. Petitioners did submit a
Motion to Supplement the Record with regard to the home office
deductions, but did not attach any documentation thereto. The
record had not been held open for this purpose, and the motion
was denied.
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Last modified: May 25, 2011