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premiums that she paid during that year for Mr. Frahm’s Wellmark
Secure Blue Select policy, and (3) during 2002 in order to
reimburse her for the premiums that she paid during that year for
Mr. Frahm’s Wellmark Secure Blue Select policy and Mr. Frahm’s
long-term care policy.33 See sec. 105(b). On that record, we
further find that the respective amounts that Mr. Frahm, as Ms.
Frahm’s employer, paid pursuant to the AgriPlan/AgriBiz medical
reimbursement plan directly to Ms. Frahm (1) during 2000 in order
to reimburse her for the premiums that she paid for Mr. Frahm’s
Wellmark Plan C policy, (2) during 2001 in order to reimburse her
for the premiums that she paid for Mr. Frahm’s Wellmark Secure
Blue Select policy, and (3) during 2002 in order to reimburse her
for the premiums that she paid for Mr. Frahm’s Wellmark Secure
Blue Select policy and Mr. Frahm’s long-term care policy consti-
tute ordinary and necessary business expenses of Mr. Frahm’s
farming business within the meaning of section 162(a).34 See
sec. 162(a)(1); sec. 1.162-10, Income Tax Regs.
We next consider the premiums that Mr. Frahm, as Ms. Frahm’s
employer, paid during 2001 to American Fidelity Assurance Company
33The Court directs the parties to determine as part of the
computations under Rule 155 the respective amounts that Mr.
Frahm, as Ms. Frahm’s employer, paid directly to Ms. Frahm during
2000 and 2001 in order to reimburse her for the premiums that she
paid during those respective years for Mr. Frahm’s Wellmark Plan
C policy and Mr. Frahm’s Wellmark Secure Blue Select policy. See
supra notes 10 and 19.
34See supra note 33.
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Last modified: March 27, 2008