- 72 - Berger also calculated the amount of dividends to be paid out by the Sley Corporations at the end of the year so as to avoid the personal holding company tax. The amount of the dividends was dictated by the amount of the taxable income of the Sley Corporations--if taxable income decreased, then dividends decreased; if taxable income increased, then dividends increased. Before 1987, there were no Forms 1099 issued to shareholders for dividends income in the form of payment of travel expenses. At some point in the period 1980-1986, Berger discussed the travel expenses paid by the Sley Corporations, with someone associated with the Sley Corporations. Berger was told that the travel and entertainment expenses were incurred so that the officers of the Sley Corporations could meet to discuss corporate business, and that there were no personal expenses included in those amounts. Berger had never seen the travel records of the Sley Corporations before the trial, nor had he heard of specific trips taken by petitioner, Betsy, and the children. If Berger would have heard of trips to the resort destinations, described under Travel and Entertainment Expenses, supra, then he would have asked whether the trips were taken for personal or business purposes. If a trip was taken for personal purposes, then Berger would not have deducted the trip expenses on the Sley Corporations’ tax return, and he probably would have treated thePage: Previous 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 Next
Last modified: May 25, 2011