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employee for the convenience of his employer. Thus, the food and
lodging expenses at issue are not section 119(a) meals and
lodging expenses.
2. Deductibility of Expenses Related to the Leasing of the
Homestead
During the years at issue, Wolf Creek Farm business
activities included leasing the homestead. It leased the
homestead, including the farmhouse, to Mr. Tschetter and received
rent in the form of a percentage of the crops grown on the farm.
Therefore, we look to the terms of the farm lease to determine
whether expenses for utilities, depreciation, and taxes are the
expenses of Wolf Creek Farm or Mr. Tschetter.
a. Property Insurance
Wolf Creek Farm deducted $667 in 1995 and $631 in 1996 for
property insurance. “Certain business-related insurance expenses
unquestionably are deductible under section 162(a).” Metrocorp,
Inc. v. Commissioner, 116 T.C. 211, 245 (2001) (citing section
1.162-1(a), Income Tax Regs.). The farm lease does not require
Mr. Tschetter to provide property insurance covering the
farmhouse or other improvements on the property. The property
insurance is an ordinary and necessary business expense of Wolf
Creek Farm (the owner of the property) and not a personal,
family, or living expense of Mr. Tschetter. We hold, therefore,
Wolf Creek Farm is entitled to deduct the insurance expenses as
claimed in each of the years at issue.
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