- 21 - The Sylva Residence was sold in February of 1991, and a small loss resulted from the sale. On audit, respondent determined that the full $65,000 transferred from YOC to Yarbrough Leasing for purchase of the Sylva Residence represented a constructive dividend from YOC to Elvin, followed by a capital contribution of $65,000 from Elvin to Yarbrough Leasing. Claimed Travel and Entertainment Expenses During 1983, 1984, and 1985, miscellaneous personal expenses of Elvin and of Mrs. Yarbrough were paid by YOC, and these expenses were claimed on YOC's corporate Federal income tax returns as deductible business travel and entertainment expenses. On audit, a portion of these claimed travel and entertainment expenses was disallowed by respondent and treated as constructive dividends to Elvin in the amounts set forth below: Amount Disallowed T and E Expenses and Treated Claimed as Constructive Year on YOC's Return Dividends to Elvin 1983 $31,048 $22,014 1984 18,209 14,012 1985 30,510 22,080 Petitioners did not introduce any records or other credible evidence in support of the proposition that the above disallowed travel and entertainment expenses qualified as deductible business expenses of YOC or that they did not represent constructive dividends to Elvin.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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