- 41 - transition in the event Mr. Duquette is no longer available to lead the company.” Those are just words; they fail to establish any corporate need for insurance should Norman’s death deprive his one-man corporation of his services. Cf. Whipple Chrysler- Plymouth v. Commissioner, T.C. Memo. 1972-55. The plan also provided a self-insured medical benefit consisting of "[p]ayment of Medical Expenses up to a maximum of $2,000 per year, per employee." That language is the basis for item (10), the $133 deduction for "medical bills". We find that, even though it covered only the two shareholder employees, the Duquettes, the plan qualified as a medical benefit plan under section 105(b), see section 1.105-5(a), Income Tax Regs., and that petitioner is entitled to deduct any medical expense payments made under the plan. Seidel v. Commissioner, T.C. Memo. 1971-238; see sec. 1.162-10(a), Income Tax Regs. Norman’s American Express bills covering the 1994 tax year (all of which were paid by petitioner) show a $25 dentist bill and a $108 charge for prescription drugs. However, the January 16, 1994, American Express statement shows both a charge and a credit for the $108, and Norman’s payment was reduced by the amount of such credit. We, therefore, find that petitioner is entitled only to a $25 deduction for medical expense reimbursements under the plan.Page: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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