- 2 - entitled to deduct them on his personal returns as Schedule C expenses. Held, the reduction of the receivable on the corporation’s books, which reduced L’s debt to the corporation and increased his net worth in a corresponding amount, is a constructive dividend to L. Alan L. Billings, for petitioners. J. Paul Knap and George W. Bezold, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION BEGHE, Judge: Respondent determined that petitioners Robert A. and Mary J. Lechner (Lechners) and Midwest Stainless, Inc. (Stainless), had the following Federal income tax deficiencies: Petitioners Taxable years Deficiencies Lechners 1994 $128 1995 24,184 Stainless f/y/e Sept. 30, 1994 $159,362 f/y/e Sept. 30, 1995 19,956 Stainless has conceded, among other things, that respondent properly disallowed a deduction claimed by Stainless for its reduction of a debt owed by Mr. Lechner, its sole shareholder, in reimbursement of his payments of legal fees incurred in defending against his indictment for filing false individual income tax returns; respondent has conceded that Mr. Lechner was entitled to deduct those fees, which he did not claim on his individualPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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