- 41 -
rent, interest, and principal the corporation owed them, and
deducted the expenses from the Dobbes’ shareholder loan account.
If this had been done with the disputed expenses, petitioners
would have had a stronger argument. The record before us
supports our finding that Holland America attempted to deduct the
personal expenses of its shareholders by disguising them as
business expenses on its Federal income tax return. Since
petitioners did not classify Holland America’s payments of Mr.
and Mrs. Dobbe’s personal expenses as loan repayments, we will
not do it for them under the circumstances involved here.
We have carefully considered all remaining arguments made by
the parties for contrary holdings and, to the extent not
discussed, find them to be irrelevant or without merit.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Last modified: May 25, 2011