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ETCO submitted, as evidence, a policy schedule for the
disability policy covering Mr. Thorpe. The schedule lists Mr.
Thorpe as the "insured" and then lists "the insured" as the
"owner". Thus, Mr. Thorpe is listed as both the owner and
insured of the policy schedule. The policy schedule shows an
effective date of July 21, 1983, and an annual premium of
$1,073.20 until July 21, 2007. Similarly, ETCO submitted an
application for insurance, which was signed by Mr. Echols, as the
"proposed insured". On the same form just below Mr. Echols'
signature, there was another signature line for the "signature of
owner/applicant (if other than proposed insured)". This
signature line was left blank indicating that the insured, Mr.
Echols, was intended to be the owner of the policy. We find this
evidence to be determinative in finding that ETCO was not the
beneficiary of the two disability insurance policies. Unlike the
taxpayer in Rugby Prods. Ltd. v. Commissioner, supra, ETCO is not
a beneficiary of the policies, and our holding in Rugby Prods.
Ltd., does not operate to preclude the deductions for the
premiums in this case. Accordingly, ETCO is entitled to deduct
the disability premiums in question.
Payments From ETCO to Mr. Thorpe and Payments to Eugene Thorpe
In the notice of deficiency sent to Mr. and Mrs. Thorpe,
respondent determined that $2,775, $2,150, and $1,800 paid to Mr.
Thorpe as advance travel allowances for the years 1990, 1991, and
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