- 9 - policies on each of the individuals. On July 1, 1983, Mr. Thorpe executed an application for disability insurance with Time Insurance Co. as the insurer. On November 4, 1989, Mr. Echols executed an application, as owner, for disability insurance with Time Insurance Co. ETCO paid the insurance premiums on both disability insurance policies and, subsequently, deducted the expenses on its tax returns for the years in issue. ETCO also maintained liability, workman's compensation, commercial auto, medical, excess liability, and casualty and surety insurance. In 1988, Mr. and Mrs. Thorpe signed two vehicle lease agreements on behalf of ETCO for two vehicles they drove during the years in issue. ETCO made the lease payments for both of the automobiles during the years in issue. Both lease agreements listed Mr. and Mrs. Thorpe as the lessees of the automobiles, and both automobiles were leased from the same company. The first lease was for a 1988 Lincoln Towncar and was dated May 10, 1988. Paragraph 24 of the lease agreement on the Lincoln contained two boxes in which the lessees could indicate that the automobile was intended to be used for either business purposes or personal use. Neither box was marked to indicate that the lessees intended to use the Lincoln for either business or personal use. The second lease was for a 1988 Mercury Colony Park and was signed July 20, 1988. Paragraph 24 of the lease agreement for the Mercury specifically designated the vehicle's use as being for business.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011