- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011