The taxpayer, who was a dentist, entered into an arrangement with an off-shore company under which that company would pay him 95% of all invoices rendered by him in the month and retained the excess of the amount collected over 95% for itself. On the basis of a finding that this arrangement was entered into by him in order to protect himself against collections falling below 95%, the amounts received by the off-shore company were deductible on the basis that (p. 257):
Insurance expenses incurred to replace income, for whatever reason, are deductible.