- 20 - In the circumstances of this case, we are loath to impute such an agreement. We also doubt that such an agreement, even if it occurred and was formally binding, would change the result generated by giving effect at face value to the corporate book entry reducing the receivable. Cf. Harwood v. Commissioner, 82 T.C. 239 (1984). We conclude that in 1994 Mr. Lechner received an additional $107,405.74 in gross income from Stainless as a constructive dividend that took the form of a debt reduction, which was evidenced by the journal entry reducing the Receivable from Officer account in the books and records of Stainless. To reflect the foregoing and the concessions of the parties, Decision will be entered under Rule 155. 8(...continued) deduction, will a repayment by the employee of an amount disallowed as a corporate deduction, be allowed as a deduction of the amount previously included in his gross income. See Pahl v. Commissioner, 67 T.C. 286 (1976); Oswald v. Commissioner, 49 T.C. 645 (1968); Rev. Rul. 69-115, 1969-1 C.B. 50.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
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