Prepare a tax research memorandum with respect to the following:Trevor owns 50 percent of the stock of an

S-corporation. During the prior year, Trevor obtained a health insurance plan providing coverage for himself, his wife, and their two children. Trevor made all of the premium payments to the plan during the prior year and furnished proof of payments to the S-corporation which then reimbursed him for the payments and reported the premium payments as wages on his W-2 for the year.

Trevor reports the amounts as gross income on his prior year personal tax return. Trevor’s income from the S-corporation exceeds the amount of premiums for the health coverage and he does not participate in any subsidized health plans maintained by another employer or an employer of his spouse. Is Trevor’s allowed to take a deduction on his personal tax return for the health insurance premiums paid during the year? State any assumptions made and cite primaryfederal tax authority.

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