W. Bradford Davis and Tedde M. Rinker - Page 13

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          appropriate.  Where petitioners presented contemporaneous                   
          documents, we have allowed the claimed amounts after adjusting              
          for any disparities between the documents and Dr. Rinker’s                  
          testimony and for computational errors.  Similarly, where the               
          original documents were lost by Mr. Hertz, but where petitioners            
          presented credible reconstructions of their expenses which carry            
          their burden of proof, we have allowed the claimed amounts after            
          adjusting for minor errors and discrepancies.                               
               B.  Particular Deductions                                              
               1.  Office Liability Insurance                                         
               Dr. Rinker testified that she paid for tort liability                  
          insurance for her medical office.  Dr. Rinker testified that                
          during 1999 her expenses for liability insurance may have been              
          about $250.  Premiums paid for business liability insurance are             
          deductible business expenses.  Sec. 1.162-1(a), Income Tax Regs.            
          Under Cohan v. Commissioner, supra at 544, we allow a deduction             
          of $125.                                                                    
               2.  Malpractice Insurance                                              
               Dr. Rinker submitted a receipt for medical malpractice                 
          insurance in the amount of $2,385.  The receipt was marked as               
          “paid” and dated January 31, 1999, and the policy apparently                
          covered February 1, 1999, through February 1, 2000.  Medical                
          malpractice insurance premiums are deductible business expenses.            
          Sec. 1.162-1, Income Tax Regs.  Although the year-long insurance            






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