- 26 - It appears that petitioner paid these expenses on behalf of Olympic in order to protect Bone and Guerrero’s investment in Olympic. They were Olympic’s sole shareholders, and any benefit from the payments would have inured to them, not to petitioner. Bone testified that he made regular trips to Washington State to motivate Olympic employees and “get things rolling”. Bone stated that he had a substantial personal investment in Olympic and that the trips he took to Washington State helped him to protect his investment. Petitioner did not have an equity interest in Olympic, and the evidence does not establish that petitioner paid the expenses of Olympic to protect petitioner’s business interests. Accordingly, respondent’s determination regarding this adjustment is sustained. 6. Insurance Expenses Respondent determined that petitioner did not fully substantiate its insurance expenses. At trial, petitioner did not address this issue in any detail. While Bone testified that petitioner was required by banking institutions to maintain insurance on the lives of the shareholders, no corroborating documentary or other evidence was offered on this point. Under these circumstances, petitioner has not shown that the insurance deduction was an ordinary and necessary business expense of petitioner. Accordingly, respondent’s determination on this issue is sustained.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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