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Boat. For 1983, 1984, and 1985, YOC did not claim depreciation
deductions relating to the Sea Ray Boat.
On audit, respondent disallowed the expenses claimed by YOC
for 1983, 1984, and 1985 relating to the Sea Ray Boat in the
respective amounts of $2,077, $3,837, and $1,228. Respondent
also determined that these amounts represented constructive
dividends to Elvin, and respondent determined that the $1,155
paid in 1983 that was not claimed by YOC as a business expense
represented a constructive dividend to Elvin.
The Motor Home
On October 11, 1983, one of YOC's customers traded in a
motor home on the purchase of a new automobile. The motor home
was then listed on YOC's books and records as an asset and was
included in YOC's used car inventory at a cost of $10,000. Elvin
used the motor home for his personal use, and he instructed YOC's
sales staff not to sell the motor home. It is not clear from the
record whether YOC claimed depreciation deductions relating to
the motor home.
During 1983 and 1984, Elvin, for his personal use and
benefit, had repairs and improvements made to the motor home at a
cost of $10,697 and $16,802, respectively. These repairs and
improvements were paid for by YOC. Of the $16,802 paid for
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