- 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 in
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