- 16 - Petitioners must show AJCS’s entitlement to the claimed deduction. See Rule 142(a). Petitioners allege in their petitions that they are entitled to deduct accrued workmen’s compensation expenses of $269,815. Respondent contends that, under section 461(h), petitioners are not entitled to the disputed workmen’s compensation insurance expense deductions because petitioners failed to substantiate that the expenses were incurred. Petitioners, in their posttrial brief, state as follows: AJCS “is also entitled to an additional insurance expense of $269,815 per IRC 162 as this expense was for workers’ compensation insurance premiums, not for tort worker’s compensation claims that are not allowed until paid per IRC 461.” At trial, petitioners’ counsel posed to John Snider, chief financial officer of AJCS, a series of generalized questions about workmen’s compensation insurance. That is the extent of petitioners’ arguments and proof. Petitioners made no attempt to explain various exhibits they submitted regarding this issue. Petitioners submitted copies of checks written from AJCS to various insurance companies. These checks totaled approximately $275,000. Petitioners also offered copies of checks remitted by W&J, Inc., to various insurance companies. These checks totaled over $800,000. On this record, we remain unaware of the relevance of checks remitted by W&J, Inc. Finally, petitionersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011