- 8 - workmen’s compensation or insurance expense had been claimed within cost of goods sold. East was the only affiliate that was shown to have deducted an insurance expense for workmen’s compensation. East’s short year return for the period ended March 31, 1993, reflects a $5,332 deduction on line 26 for “W/C insurance”, and East’s Schedule M-1 reflects a “W/C accrual” of $83,536. No workmen’s compensation insurance deduction is listed on East’s March 31, 1994, return. OPINION Petitioners were the shareholders of AJCS, an S corporation. Accordingly, any adjustment to AJCS flows through to petitioners. Respondent determined that several adjustments were necessary to items reported on AJCS’s 1993 return, resulting in flowthrough adjustments and income tax deficiencies for petitioners’ 1993 taxable year. I. AJCS’s Expenditures in Connection With the Contracts Transferred to the Affiliates The first issue for our consideration is whether AJCS’s expenditure of $2,261,555 is deductible as AJCS’s ordinary and necessary business expenses or whether those expense obligations pertained to the four affiliates.8 8 With respect to the $2,261,555 adjustment, respondent has abandoned his alternative argument under which allocations of the $2,261,555 in expenses would have been made to the four (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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