Charles L. Fields and Barbara S. Fields - Page 27

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          on petitioners' home.  Respondent determined that the 1981                  
          dividend resulted from:  (1) BarSon's payment of $7,500 to Finley           
          Kumble for petitioners' personal legal fees, (2) BarSon's payment           
          of $2,728 for petitioners' personal promotion expense,                      
          (3) BarSon's payment of $6,987 for petitioners' personal travel,            
          and (4) petitioners' personal use of an automobile ($2,295).                
          Petitioners allege that:  (1) BarSon's $2,500 payment in 1980 was           
          for professional fees rendered to BarSon, (2) the $1,000 and                
          $18,635 amounts were charged to petitioner's loan account, and              
          later repaid, (3) BarSon's $7,500 payment in 1981 was for                   
          professional fees rendered to BarSon, and (4) the $2,728, $6,987,           
          and $2,295 amounts were ordinary and necessary business expenses            
          of BarSon.                                                                  
               We agree with respondent that the subject amounts are                  
          includable in petitioners' gross income as dividends.                       
          A shareholder's gross income includes his or her receipt of any             
          dividend, regardless of whether the dividend was formally                   
          declared by the corporation.  Sec. 61(a)(7); Loftin & Woodard,              
          Inc. v. United States, 577 F.2d 1206, 1214 (5th Cir. 1978).                 
          Where a shareholder receives a distribution of corporate funds              
          for his or her personal benefit, the distribution may be taxed to           
          the shareholder as a dividend to the extent of the corporation's            
          earnings and profits.  Ireland v. United States, 621 F.2d 731,              








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