- 51 -
T.C. 387, 394 (1955). Resyn's records are not sufficient to show
Resyn's and petitioner's intent; rather, we believe the recording
of petitioners' personal expenses as loans from Resyn was part of
petitioner's scheme to avoid reporting income.
Petitioners argue that the facts here are like those in
Boshwit Bros., Inc. v. Commissioner, T.C. Memo. 1982-156. We
disagree. In that case, we found that the corporation made loans
to its shareholder because we believed the shareholder's
testimony that he intended to repay the loans and because the
account showed regular credits and a decreasing balance. Id.
Here, petitioner did not show that he intended to repay the loan
or that Resyn gave him regular credits for loan repayments.
Thus, petitioners' reliance on Boshwit Bros. is not persuasive.
5. Traceable Amounts
Petitioners point out that respondent could not trace all of
the funds that petitioner diverted to the Polymer account. This
fact does not help petitioner because the determination is valid
and, as discussed below at section F-2, respondent traced
significant amounts to petitioners for each year by clear and
convincing evidence.
Petitioners contend that petitioners should be charged with
constructive dividends only for amounts that respondent can prove
were spent for petitioners' personal benefit. We disagree.
Respondent determined that all deposits in the Polymer and
Chemical Traders accounts during the years in issue are income to
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