- 10 - affd. 85 Fed. Appx. 875 (3d Cir. 2003). Mr. Cotler argues that although the firm wrote the checks that paid for the Standard policy, he reimbursed the firm for the amount of his premiums by deducting these amounts from his shareholder loan account. In Bouquett v. Commissioner, T.C. Memo. 1994-212, a corporation paid the premiums on the taxpayer’s disability policy. In Bouquett, we held that the corporation was nothing more than a conduit that paid the premiums nominally and then collected the premium payments from the employees. Mr. Cotler reimbursed the firm by subtracting the amounts of the insurance premiums from his loan to the firm. Mr. Cotler’s firm was nothing more than a conduit. Ms. Marlane and Mr. Gladstone credibly testified that Mr. Cotler had a longstanding and consistent practice of not paying personal expenses with corporate funds. From the inception of the Standard policy until premiums were waived, Mr. Cotler treated the premiums as personal items, he paid his share of the premiums during the years in issue through his loan account, and the firm never deducted them on its Forms 1120. Respondent argues that Mr. Cotler failed to reimburse his firm for the premiums on the Standard policy. Respondent further argues that the bookkeeping entries and the shareholder loan receivable document do not demonstrate that Mr. Cotler actually paid the premiums on the Standard policy. We disagree. SincePage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007