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have to find that he worked for JJH without compensation. We
decline to do so.
Petitioner did not respect the separateness of JJH, and he
commingled his income and expenses with JJH’s. Petitioner
maintained no personal checking accounts, and he treated JJH’s
account as his own. Petitioner had dominion and control over the
account, and he readily admits that he used it as his own,
boasting at trial: “my home, my style of living, is paid for by
Joseph J. House, Inc.”, and that "personal checkbooks are not a
good thing". See Denali Dental Services v. Commissioner, T.C.
Memo. 1989-482 (corporation a sham where its checking account was
used as a “pocketbook” for payment of shareholder’s personal
expenses). JJH did not keep separate books and records of the
deposits, checks, transfers, or withdrawals from JJH’s account to
differentiate between business and personal income and expenses.
Instead, petitioner treated his affairs as one and the same with
JJH’s.
JJH had no management other than petitioner, and petitioner
acknowledged that he was in complete control of JJH.
Petitioner’s contention that Charlene and Craig were officers of
JJH does not stand up in the face of the evidence, which shows
that they had nothing to do with its activities. In discussing
the use of the family corporations, petitioner admitted that
"This whole operation, this whole function, is my responsibility
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