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any evidence as to the existence or nature of any bona fide
business discussion either before or after the entertainment.
See sec. 1.274-2(d)(3), Income Tax Regs., sec. 1.274-5T(b)(3)(iv)
and (b)(4), Temporary Income Tax Regs., 50 Fed. Reg. 46015
(Nov. 6, 1985). Therefore, the entertainment expense is
nondeductible.
Item (8), the cost of insurance for the automobile, was
incurred on May 28, 1994, more than 4 months after the Dallas-
Phoenix round trip, the only demonstrated business use of the
auto during the audit year. Because there is no evidence that
the $297 payment of automobile insurance was attributable to
other than periods of personal use of the auto during the 1994
tax year, we find that no portion of this payment constitutes a
deductible expense under section 162(a).
Petitioner argues that item (9), a premium for life
insurance on Norman’s life, was purchased pursuant to a company
plan or policy adopted on February 6, 1992, by Norman acting in
his capacity as petitioner’s president (the plan). The plan
provided for "[l]ife insurance offered through American Express
on the life of * * * [Norman]", and was limited to life insurance
"covering accidents while traveling". There is no evidence as to
the amount of the insurance in question. Apparently, the
proceeds of the policy were payable to petitioner: “The proceeds
from the policy will be used to effect an orderly business
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