- 38 - the effect is the same as if the third party had paid the taxpayer who in turn paid his creditor. Old Colony Trust Co. v. Commissioner, 279 U.S. 716 (1929). Moreover, transactions between closely held corporations and their shareholders warrant close scrutiny. Paula Constr. Co. v. Commissioner, 58 T.C. 1055, 1058 (1972), affd. without published opinion 474 F.2d 1345 (5th Cir. 1973); Electric & Neon, Inc. v. Commissioner, 56 T.C. 1324, 1339 (1971), affd. without published opinion 496 F.2d 876 (5th Cir. 1974). In this instance, all of these aforementioned items were charged as corporate expenses. Petitioners did not report them on their income tax returns. They contend that these items were not items of income but were reimbursements for their payments of corporate expenses. Petitioners have submitted incomplete corporate records for the taxable years in question. The checks submitted as evidence merely represent payment by the corporations to petitioners. Also, petitioners did not offer as exhibits any substantiation of the expenses allegedly incurred on behalf of the corporations. For example, Mr. Bowden did not proffer any of his credit card bills that were paid by the corporations which would have provided an opportunity to scrutinize the basis for the payments. Paula Constr. Co. v. Commissioner, supra. Some of the disputed items were facially questionable. For example, PWIC paid $700Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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