Ragnhild A. Westby - Page 48

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          is deductible.  The additional documented amounts total $1,096.51           
          (Ex. 40-R, lines 474-476, 479, 481-482).                                    
               (h) During 1990, petitioner paid employee life insurance,              
          employee health insurance, and workers’ compensation and                    
          unemployment insurance totaling $1,543.64, all of which                     
          respondent concedes are deductible (Ex. 41-R, lines 9-14, 842-              
          843; SSR dated 9/10/99).                                                    
               (i) During 1990, petitioner also made payments to Blue                 
          Cross/Blue Shield, Sid Murray Co. and Mutual of Omaha for office            
          and travel insurance ($518.98) that petitioner documented and               
          respondent concedes are deductible (Ex. 41-R, lines 365-368, 378-           
          379).                                                                       
               (j) During 1990, petitioner made other insurance payments,             
          the amount and business purpose of which she documented at trial.           
          Although respondent does not concede that these payments are                
          deductible, we hold that they are deductible because petitioner             
          has credibly testified with regard to their business purpose.               
          The payments total $1,303.19 (Ex. 41-R, line 369).                          
               Petitioner is entitled to deduct business insurance that she           
          paid in each of the years at issue in the amounts summarized                
          above and shown on the chart at page 79 of this opinion.                    
                         j.  Utilities                                                
               For the years at issue, petitioner claimed deductions for              
          utilities as follows:                                                       






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