- 9 - dues and publications expense. Additionally, Reader's Digest billed Mr. Christal for Condensed Books at his home address. United Sovereigns paid the outstanding bill and claimed the expense as a dues and publications expense. Mr. Christal submitted receipts from restaurants or grocery stores for food purchases as substantiation for United Sovereigns' office supplies and "promo" expenses. Additionally, Mr. Christal submitted receipts, which referenced Mrs. Christal, from Matol Botanical International for the purchase of five bottles worth $35 each as substantiation of United Sovereigns' office expenses. Throughout 1992, $6,900 was withdrawn as petty cash from United Sovereigns' checking account. Petitioners maintained no record of how that cash was spent. OPINION Petitioners contend that United Sovereigns is a valid entity, legally independent and separate from Mr. Christal as an individual, and that United Sovereigns and the transactions in which it took part should be respected for Federal tax purposes. Respondent contends that United Sovereigns is a sham, it has no economic substance, and United Sovereigns existed for no purpose aside from being used to obtain tax benefits for petitioners; thus, the income of United Sovereigns is taxable wholly to petitioners. We agree with respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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