- 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...)
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