- 13 - 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 insurancePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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