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BEECH TRUCKING CO. v. COMMISSIONER

Docket No. 16452-99.

118 T.C. 428 (2002)

118 T.C. No. 27

BEECH TRUCKING COMPANY, INC., ARTHUR BEECH, TAX MATTERS PERSON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 23, 2002.

Attorney(s) appearing for the Case

James Allen Brown, for petitioner.

Edith F. Moates and John S. Repsis, for respondent.

THORNTON, Judge:

By notice of final S corporation administrative adjustment (FSAA), respondent determined adjustments of $251,885 and $286,878 to the ordinary income of Beech Trucking Co., Inc. (Beech Trucking), for 1995 and 1996, respectively. At issue is the amount that Beech Trucking may deduct with respect to per diem allowances it provided drivers that it leased from an affiliated company, and, more particularly, whether the 50-percent limitation of section...

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