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incorrectly reflected as an increase in the outstanding balance
of the YOC-Elvin Account. Petitioners also stress that after
1986 significant, additional repayments were made by Elvin to
reduce the debit balance of the YOC-Elvin Account and that
respondent has not given Elvin credit for these later repayments.
Weighing all of the relevant facts in this case, we agree
with respondent's determinations. We conclude that for each year
in issue, the YOC-Elvin Account did not constitute a valid loan
account and that the net increase each year in the outstanding
debit balance of the YOC-Elvin Account represents a constructive
dividend to Elvin (namely, for 1983 -- $137,673, for 1984 --
$17,510, for 1985 -- $64,825, and for 1986 -- $258,939).
Elvin's self-serving testimony that he withdrew money from
YOC in good faith and that he intended to fully repay YOC is
entitled to little weight. See Williams v. Commissioner, 627
F.2d 1032 (10th Cir. 1980), affg. T.C. Memo. 1978-306. With
regard to the YOC-Elvin Account, no loan documents or other
promissory notes were executed, no maturity dates existed, no
repayment dates were established, and no limits were placed on
the amount of funds that Elvin could withdraw from YOC for his
personal benefit. Elvin did not provide any collateral to secure
the transfers that YOC made to Elvin.
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