Deductibility of COBRA as business exp in parent/sub situation

[Happy Camper]

I have a TP with several limited Partnerships owned by two LLC's. TP is sole shareholder of the LLC's. TP was on COBRA in 2015 from another company that he used to be >2% SH. COBRA premiums have been paid by one of the partnerships and is showing as a business expense. TP has other employees and does not offer group health insurance to any other employees.

Question: Can the COBRA premiums be deducted as a business expense on the Partnership? TP currently has no W-2 income from that partnership.

Is there another way the TP can deduct COBRA premiums besides on Sch A?- ie: if the LLC paid them

Could TP possibly be subject to health reimbursement penalties?

Trying to get a handle on this to give options before the open enrollment is over. Thanks for input!

[taxea]

Have you read the publication or TTB info on this issue?

[Happy Camper]

Yes, I am aware of the nondeductibility of COBRA as SEHI

Yes I have, I am aware of the non-deductibility of COBRA as SEHI, however the fact that the TP's COBRA is being paid by the partnership (of which TP is not technically a partner ie: does not receive K-1) is throwing me off.

It kind of seems like it would fit more into the HRA realm, but then from what I can tell, TP could be subject to penalties as there are more than 2 employee's and no other employee receives reimbursements for health insurance. At least after June 30, 2015. But even at that, should the 'reimbursement' be reported as income on a W-2?

Or am I mixing lots of apples with oranges?