Clifford L. Brody and Barbara J. Declerk - Page 12

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          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).  It            






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