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home mortgage application. Respondent determined that $10,000 of
the $20,000 amount was a constructive dividend to petitioners
because the legal advice pertained to petitioners' personal
matters. Respondent determined that $2,500 of this dividend was
paid in 1980 and the balance in 1981. Respondent also determined
that petitioners used BarSon's checks in 1980 to pay for $1,000
of their personal expenses, that BarSon paid $2,728 in 1981 for
petitioners' personal promotion expense, that BarSon paid $6,987
in 1981 for petitioners' personal travel, and that petitioners
received a $2,295 constructive dividend from BarSon in 1981,
stemming from their personal use of an automobile.
Petitioner did not personally withdraw money from CAI's
accounts. Petitioner directed Mr. Quin to send money from CAI's
accounts to designated payees, and Mr. Quin directed the Bank to
disburse CAI's funds according to petitioner's directions. From
1980 to 1982, most of CAI's disbursements went to petitioner or
to third parties designated by petitioner for his benefit.
In July 1981, CAI formed two new accounts (the A and B
accounts) at the Bank, and the C account remained as CAI's
operating account. Petitioner controlled the A account, and the
balance therein stemmed from income for his services. Dr. Young
controlled the B account, and the balance therein stemmed from
income for his services. Petitioner withdrew $291,936 from the C
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