Wilburn C. Hall, Jr. - Page 56

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        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...)           




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