Eugene A. Beck, et al. - Page 38




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          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 in            






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