- 5 -
I.D. Club. Petitioner argues that the corporate identity should
be disregarded because he did not think of it as a separate
entity from himself. While this may be the case, petitioner is
the one who elected the corporate form for I.D. Club when it was
initially created. Petitioner received the benefits of the
election of the corporate status for I.D. Club. Moreover, I.D.
Club was operating as a corporation when petitioner entered into
agreements on I.D. Club's behalf. I.D. Club was created with a
real business purpose, and, in its initial operations, it
conducted legitimate business transactions. I.D. Club was not a
sham corporation. There is no reason why we should disregard the
corporate entity. Accordingly, petitioner is not entitled to
deduct expenses of I.D. Club. We sustain respondent's
determination.
To reflect the foregoing,
Decision will be entered
for respondent in the amount
of the reduced deficiency.
Page: Previous 1 2 3 4 5
Last modified: May 25, 2011