- 22 - Additional Personal Expenses of Elvin Paid by YOC and Claimed by YOC as Deductible Business Expenses During 1983 through 1986, YOC paid numerous additional personal expenses of Elvin that were claimed by YOC as deductible business expenses. Elvin instructed YOC's employees to pay these expenses and to reflect these expenses in YOC's books and records as YOC's business expenses. The schedules below set forth by year the amount of these additional personal expenses of Elvin that YOC paid and claimed as deductible business expenses. The schedules also indicate the manner in which these expenses were reflected in YOC's books and records and the benefit that Elvin received as a result of the expenses. On audit, respondent disallowed the business expense deductions claimed by YOC with respect to the expenses set forth in the schedules, and respondent treated them as constructive dividends to Elvin. In a number of instances (identified as "Not deducted" in the column reflecting the manner in which the expenses were treated on YOC's books), respondent determined (with respect to certain expenses that were paid by YOC for Elvin's benefit but not deducted as business expenses by YOC) that such expenses represented constructive dividends to Elvin. The schedule also reflects which expenses petitioners now concede should be treated as nondeductible personal expenses and as constructive dividends to Elvin.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011