Marcos Eliseo and Teodora C. Escobar De Paz, et al. - Page 11




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          current existence) of the various insurance policies of the                 
          owner-operators.  Therefore, it makes sense to try to cover as              
          many as possible by blanket policies, under which insurance                 
          companies require that the insured have an ownership interest in            
          the vehicle, which in turn is satisfied by the lease arrangement.           
          However, in most if not all cases, the owner-operators pay for              
          this insurance by having its cost deducted from their hauling               
          proceeds.                                                                   
               Accordingly, we conclude that for income tax purposes the              
          lease arrangements with the carriers had no independent economic            
          significance, all the income the owner-operators received from              
          the carriers was wage income, and the expenses pertaining to the            
          operation of the trucks are deductible as itemized deductions on            
          Schedule A, subject to the limitations of section 67(a).                    
               To reflect the foregoing,                                              
                                                  Decisions will be entered           
                                             under Rule 155.                          


















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