- 56 - 264; Crouch v. United States, 692 F.2d 97, 99 (10th Cir. 1982). While unusual cases may require disregard of corporate form, Burnet v. Commonwealth Imp. Co., 287 U.S. 415, 419 (1932), we think the record in the instant case fails to disclose any circumstances sufficient to support such a disregard. Also, petitioner has failed to persuade us that his expenditures for the benefit of any of the Corporations are ordinary and necessary expenses of any trade or business of petitioner's. See Lohrke v. Commissioner, 48 T.C. 679 (1967). As to the legal status of the Corporations under Oklahoma law and the effect of this status on Federal tax law, see United States v. Young, 604 F. Supp. 164 (N.D. Okla. 1984). In addition, as can be seen from table 1, supra, at any given moment during the 5 years in issue, at least 1, and sometimes as many as 10, of the Corporations not only was in existence but also was in good standing. From the foregoing we conclude, and we have found, that the expenses of the Corporations are not expenses of petitioner, or of his trade or business, and thus are not deductible by petitioner. We hold for respondent on this issue. 18 18At trial, petitioner suggested that he, rather than the Corporations, was engaged in trades or businesses in addition to petitioner's law practice and Hall Farms, and that he reported his "cash revenue" from those activities on line 7 of the Forms 1040, the line for wages, etc. We pointed out that this was inappropriate for various reasons and, more to the point, our (continued...)Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
Last modified: May 25, 2011