Yarbrough Oldsmobile Cadillac, Inc. - Page 48

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          business expenses.  Petitioners argue that Elvin, on behalf of              
          YOC, entertained potential customers, some of whom purchased new            
          automobiles from YOC on an annual basis.  Petitioners argue that            
          General Motors encouraged Elvin to entertain potential customers            
          and that entertainment was a necessary expense to attract                   
          purchasers of high-priced Cadillac automobiles.                             
               Respondent argues that petitioners have not substantiated              
          the business, as opposed to the personal, nature of any of the              
          claimed travel and entertainment expenses that respondent                   
          disallowed and treated as constructive dividends to Elvin.                  
               Petitioners have not offered any documentary evidence or               
          other credible substantiation to support the business nature of             
          the claimed travel and entertainment expenses disallowed by                 
          respondent.                                                                 
               We sustain respondent's determination that for 1983, 1984,             
          and 1985, the claimed travel and entertainment expenses of                  
          $22,014, $14,012, and $22,080, respectively, are to be                      
          disallowed, and Elvin is to be treated as receiving constructive            
          dividends for the same years and in the same amounts.                       

          Additional Personal Expenses of Elvin Paid by YOC -- Claimed                
          Business Expenses and Constructive Dividends                                
               Petitioners make no persuasive argument and offer no                   
          credible evidence that any of the expenses in question under this           
          category (1983 -- $65,487; 1984 -- $43,495; 1985 -- $74,798; and            
          1986 -- $15,136) qualify as valid business expenses of YOC.  Many           




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