BobKamman
Level 15
04-08-2021
11:32 PM
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Except the word "paid" does not appear anywhere in that reference:
(i) The specified premiums less the premium tax credit attributable to the specified premiums;
And the definition of "specified premiums" in 1.162(l)-2 seems to be referring to the situation where the policy also covers non-dependents.
I would let the client make the choice between protecting his pocketbook or protecting the revenue. Most self-employed taxpayers are willing to claim benefit of the doubt when government regulation is vague.