- 38 - mistake or poor judgment, Iley v. Commissioner, 19 T.C. 631 (1952). Although these omissions are substantial enough to indicate fraudulent intent, the omissions alone are not so substantial as to unequivocally indicate fraudulent intent, and we consider them in the context of the entire record. Candela v. United States, 635 F.2d 1272, 1274 (1980); Recklitis v. Commissioner, supra at 909; Wheadon v. Commissioner, T.C. Memo. 1992-633; cf. Kramer v. Commissioner, 389 F.2d 236 (7th Cir. 1968), affg. T.C. Memo. 1966-234. Mr. Beck believed that payment by the corporation of an expense tied to the corporation was proper. For example, the corporation paid for the expenses incurred at the cabin and deducted them as expenses related to the annual stockholders' meeting. The corporation owned the condominiums where Mr. Beck and Michael resided. The corporation paid expenses related to the condominiums and deducted the expenses on its return. Similarly, expenses for the vehicles used by Mr. Beck and Michael were deducted. The corporation paid for many of Mr. Beck's meals. Mr. Beck believed that the payment and deduction was proper because he discussed the activities of the liquor store or was entertaining customers or suppliers of the store. The corporation paid for Mr. Beck's travel expenses to Las Vegas. The corporation's savings at the better exchange rate inPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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