- 11 - KOA. KOA’s expenses included its corporate bills and premiums for key man insurance. (1) Key Man Insurance While the record does not contain a copy of the key man insurance policy, such insurance is generally understood to be life insurance taken out by a company on an essential or valuable employee, with the company as the beneficiary, as is the case here. See Black’s Law Dictionary 945 (8th ed. 2004). Petitioners are not entitled to deduct the payments representing insurance premiums. (2) Vehicle Expense We now consider petitioner Brody’s claimed vehicle expense deduction of $5,059. Deductions for travel and transportation expenses otherwise allowable under section 162(a) are subject to strict substantiation requirements. See sec. 274(d)(1); sec. 1.274-5T, Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). The record does not contain any evidence indicating whether KOA had a reimbursement policy for employee travel expenses or that petitioner Brody complied with the substantiation requirements. Respondent’s disallowance of this deduction is sustained. (3) Loan/Debt In general, there is allowed as a deduction “any debt which becomes worthless within the taxable year.” Sec. 166(a)(1). ItPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011